UK Supreme Court confirms English law governs arbitration agreement seated in Paris In UniCredit Bank GmbH v RusChem Alliance LLC [2024] UKSC 30, the UK Supreme Court ruled that English law governed the arbitration agreement, despite the arbitration being seated in Paris, as it applied to the main contract with no contrary indication. Articles Jasmin Sandhu Published: October 14, 2024 Contact author Download article pdf UniCredit Bank GmbH v RusChem Alliance LLC [2024] UKSC 30 In this recent case, the UK Supreme Court examined two key issues: the governing law of the arbitration agreement and the appropriate forum for granting an anti-suit injunction. Background:  UniCredit Bank issued seven on-demand bonds governed by English law in favour of RusChemAlliance (RCA). Due to EU sanctions on Russia, UniCredit refused payments under these bonds. In response, RCA initiated legal proceedings in the Russian courts to enforce the bonds, despite the arbitration agreements in the bond contracts providing for ICC arbitration with Paris as the seat. UniCredit sought an anti-suit injunction from the English courts to prevent RCA from continuing the Russian proceedings, arguing that RCA’s actions breached the arbitration agreement. Key issues:  Governing law of the arbitration agreement: The Supreme Court confirmed that English law governed the arbitration agreement, even though the arbitration was seated in Paris. Following the principle established in Enka v Chubb, it confirmed that the governing law of the main contract (in this case, English law), also applies to the arbitration agreement unless expressly stated otherwise. The Court rejected RCA’s argument that French law should apply simply because the arbitration was seated in Paris. Proper place for the anti-suit injunction claim: The Court held that England was the correct forum to issue an anti-suit injunction, as the arbitration agreement was governed by English law and the French courts (as the supervisory co