In its recent decision in Corporacion AIC, SA v. Hidroelectrica Santa Rita S.A., the U.S. Court of Appeals for the Eleventh Circuit, sitting en banc, held that the Federal Arbitration Act’s (FAA’s) Chapter 1 vacatur grounds apply to nondomestic awards, thereby overturning prior panel precedents and joining the rest of the federal circuits.

Corporacion concerns the vacatur standards for international arbitration awards rendered in the United States: specifically, whether those standards are supplied by Chapter 1 of the Federal Arbitration Act (also governing domestic awards) or Article V of the New York Convention.