THERE has for a long time been a general uncertainty as to the laws and attitudes of Middle Eastern countries1 to arbitration as a mechanism for resolving disputes arising out of international commercial arrangements. This has been expressed by the oft-profferred advice to be wary of submitting to arbitration disputes with parties from the Middle East. This situation is due in large part to ignorance in the West about Islam, which is a major influence on the laws of most all the Arab countries, ambiguity in the policies as expressed by the Governments in the region, and misunderstanding of Middle Eastern thinking. Arbitration has always been the most practical method for resolving disputes involving Middle Eastern parties. Although the law in many Middle Eastern countries has given rise to uncertainty and insecurity with respect to the effectiveness of the arbitration agreement and award, the Governments and Government entities of the Arab countries have regularly agreed to an arbitration provision in contracts with Western parties, and disputes arising out of such contracts have been submitted to arbitration and in most cases the awards made have been voluntarily accepted. In particular, in the 1950's and 1960's there were a series of arbitrations concerning the effect and extent of oil concession agreements granted by the Middle Eastern Governments over their territory.2 In recent years there have been an increasing number of arbitrations involving State3 and private entities from the Middle East and arising out of agency and distribution arrangements, turn-key projects and construction contracts.4 In most of these cases the awards have been accepted and given effect to, although there have been cases where enforcement has been sought. The misconceptions about arbitration involving parties from the Middle East has resulted from two principal facts. First, the absence in many …