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Bermuda has two separate and distinct systems of arbitration. The first, which applies to international commercial arbitration, is under the Bermuda International Conciliation and Arbitration Act 1993 and adopts the UNCITRAL Model Law. The second, under the Arbitration Act 1986, applies to all arbitrations that are not international commercial arbitrations and adopts the law which applied in England before the 1996 reforms.

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