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Jul 28, 2026·Law Innovation and Technology
0 cites
Decentralised autonomous organisations and the future of arbitration: a critical examination of on-chain and off-chain mechanisms

Pınar Çağlayan Aksoy, Yaren Alparslan

Decentralised Autonomous Organisations (DAOs) raise fundamental questions for private law. While scholarly and regulatory attention has primarily focused on the legal status and governance of DAOs, comparatively little consideration has been given to how disputes involving these organisations should be resolved. This article examines the suitability of dispute resolution mechanisms for DAO-related disputes. Analysing the principal categories of disputes that have emerged in practice, the article critically evaluates blockchain-based dispute resolution mechanisms alongside traditional arbitration, in light of due process, enforceability, party autonomy, and the unique features of decentralised governance. It argues that neither purely code-based dispute resolution nor conventional litigation provides a satisfactory response to the complexity of DAO disputes. It concludes that arbitration, appropriately adapted to the technological and organisational realities of DAOs, offers the most promising framework for balancing decentralisation, legal certainty, and procedural fairness within the evolving Web3 ecosystem.

Open access
Dispute Resolution and Class Actions
Energy Law and Policy
International Arbitration and Investment Law
Original source
May 6, 2026·Liverpool John Moores University
0 cites
Cryptocurrency Payments in International Contracts

Mehrnoosh Khajvand

The rise of cryptocurrency has revolutionised value exchange and contractual execution in international trade. This article assesses whether existing legal and arbitral frameworks adequately ensure certainty, fairness, and enforceability in international cryptocurrency contracts. Employing doctrinal and comparative legal analysis, it examines the legal and regulatory framework of crypto-assets and smart contracts across jurisdictions in both the Global North (including the UK and the EU) and the Global Majority (such as India and Iran). Within some evaluations of regulatory approaches, such as UNIDROIT and MiCA, the research finds that while some jurisdictions in the Global North have made progress in establishing regulatory frameworks that recognise crypto-assets as property and promote the enforceability of smart contracts, they still face significant challenges. These obstacles are even more pronounced in Global Majority countries, where regulatory strategies tend to be prohibitive or fragmented. Decentralised innovations like Decentralised Finance (DeFi) and Decentralised Autonomous Organisations (DAOs) further complicate governance and cross-border recognition. The article also investigates the impact of international arbitration, particularly under the New York Convention and UNCITRAL Model Law. The findings reveal that, while these instruments support cross-border enforcement, they face challenges inherent to cryptocurrency, including issues with arbitration agreements, pseudonymity, public policy objections, and the volatility of damages. Blockchain’s decentralised structure further complicates the determination of an arbitral seat. Although crypto arbitration platforms are emerging as an innovative potential, their lack of connection to national legal systems renders them largely unenforceable. Integrating digital currencies into domestic legal frameworks may mitigate these concerns; however, effectiveness hinges on global acceptance, which remains fragmented across jurisdictions. In conclusion, the findings submitted that, despite notable progress, considerable gaps remain in both legal and arbitral frameworks concerning cryptocurrency. The key recommendations are to harmonise international legal and arbitral frameworks, establish more explicit rules for blockchain evidence, enhance privacy protections, and adopt hybrid arbitration methods that combine decentralised approaches with established practices. These measures aim to strengthen regulatory cooperation and ensure stability in cross-border cryptocurrency transactions.

Open access
Blockchain Technology Applications and Security
Security, Politics, and Digital Transformation
International Arbitration and Investment Law
Original source
Jan 1, 2026·SSRN Electronic Journal
0 cites
Blockchain Technology, Brics Pay Consortium, And the Private International Challenges of Decentralized Autonomous Organizations (Daos)

Tolulope Falokun

The emergence of Decentralized Autonomous Organizations (DAOs) represents a paradigm shift in organizational governance, replacing traditional corporate structures with algorithmically governed models on blockchain networks. This article provides an analysis of the private international law (PIL) challenges posed by the BRICS Pay Consortium, a proposed decentralized payment messaging system for BRICS member states, modeled on DAO principles. The BRICS Pay Consortium DAO highlights a fundamental tension between the transnational and often decentralized nature of blockchain and conventional territorial legal frameworks. The Consortium is designed to operate without a central headquarters or legal personality, thus undermining traditional PIL connecting factors—such as domicile, registered office, and principal place of business—used to determine jurisdiction and applicable law. The article examines divergent global framework for the regulation of DAOs. By evaluating current responses—including statutory legal wrappers and on-chain dispute resolution—this article demonstrates that existing doctrines are inadequate for decentralized entities. It concludes that existing frameworks on jurisdiction and choice of law are currently inadequate for the complexities of the BRICS Pay Consortium DAO. Ultimately, the article argues that resolving these challenges requires a transition from traditional territorial models toward regulatory innovation, contractual best practices, and cross border cooperation.

Open access
International Arbitration and Investment Law
Global Financial Regulation and Crises
Dispute Resolution and Class Actions
Original source
Nov 28, 2024·IEEE Transactions on Reliability
24 cites
Guardians of the Ledger: Protecting Decentralized Exchanges from State Derailment Defects

Zongwei Li, Wenkai Li, Xiaoqi Li, Yuqing Zhang

The decentralized exchange (DEX) leverages smart contracts to trade digital assets for users on the blockchain. Developers usually develop several smart contracts into one project, implementing complex logic functions and multiple transaction operations. However, the interaction among these contracts poses challenges for developers analyzing the state logic. Due to the complex state logic in DEX projects, many critical state derailment defects have emerged in recent years. In this article, we conduct the first systematic study of state derailment defects in DEX. We define five categories of state derailment defects and provide detailed analyses of them. Furthermore, we propose a novel deep learning-based framework StateGuardfor detecting state derailment defects in DEX smart contracts. It leverages a smart contract deconstructor to deconstruct the contract into an abstract syntax tree (AST), from which five categories of dependency features are extracted. Next, it implements a graph optimizer to process the structured data. At last, the optimized data is analyzed by graph convolutional networks to identify potential state derailment defects. We evaluated StateGuardthrough a dataset of 46 DEX projects containing 5671 smart contracts, and it achieved 94.25% F1-score. In addition, in a comparison experiment with state-of-the-art, StateGuardleads the F1-score by 6.29%. To further verify its practicality, we used StateGuardto audit real-world contracts and successfully authenticated multiple novel common vulnerabilities and exposures.

Open access
2 source records
cs.SE
cs.CR
State Capitalism and Financial Governance
Original source
Nov 21, 2024·International Journal For Multidisciplinary Research
0 cites
Navigating The Legal And Regulatory Landscape Of DAOs: A Global Perspective

S. R, Sai Roshan M.G. -

DAOs (Decentralized Autonomous Organizations) are fundamentally changing how companies are run in several key ways, through decentralized decision-making, social audibility, and limited liability principle. The following research examines the changes that DAOs bring to conventional corporate governance and analyses how they are being implemented worldwide. DAOs have advantages that include the decentralization of power, and the ability to improve the speed with which innovation occurs. However, they present obstacles that include legal uncertainty, problems of governance, and security vulnerabilities. This research comprehensively examines how DAOs could disrupt corporate processes such as decision-making, stakeholders’ interactions, and power relations. It then reviews the current legal and regulatory environment for DAOs across different legal systems and considers the notion of liability issues. The research also presents a checklist of strengths and weaknesses for DAOs in emerging markets based on considerations such as technology adaptation, regulatory definition, and community engagement. When the trends of socioeconomic impacts are unveiled, it will be possible for lawmakers, managers, and investors to adapt to new conditions and utilize the evolved concept of corporate governance through DAOs.

Open access
International Arbitration and Investment Law
Public-Private Partnership Projects
Original source
Feb 21, 2024·The Journal of World Investment & Trade
6 cites
A BIT of Protection for Non-Fungible Tokens: Digital Assets as a Catalyst for Economic Growth

Nicolette Butler, Jasem Tarawneh

Abstract An inevitable consequence of technological advancement is that it triggers regulatory challenges for law and policymakers. The regulation of digital assets has generated much debate in this regard. The central objective of this article is to examine the regulation of one particular type of digital asset, NFTs, through an international investment law lens. The international investment regime offers investors high levels of protection against breaches of obligations by host states for covered investments. The aim of the article is to determine whether NFTs can be considered as covered investments for the purposes of the application of bilateral investment treaties (BITs) and treaties with investment provisions (TIPs), and further to examine whether that regime would provide an appropriate regulatory framework for investment in NFTs.

Open access
International Arbitration and Investment Law
Original source
Jan 1, 2024·XXI međunarodni naučni skup „Pravnički dani - Prof. dr Slavko Carić“, Odgovori pravne nauke na izazove savremenog druĆĄtva - zbornik radova
0 cites
Artificial intelligence and distributed ledger: Upgrading of international trade relations

Milan Mitić

Artificial intelligence (AI) and distributed ledger (DLT), although technically diametrically opposed technologies, have many common features in international trade relations (MTO). The mentioned technologies are at the same time emerging technologies and disruptive technologies. On the other hand, MTO consists not only of entities, but also concrete business relationships, ie business operations. In this sense, AI and DLT are the subject of both international economic law and international trade law. Both technologies are viewed in the light of the digitalization of trade (economy) with the aim of automating it as much as possible. Automation is one of the key features that AI and DLT have in common. Preoccupied with AI and DLT, UNCITRAL, UNESCO, the World Trade Organization (WTO) and the European Union (EU) have made significant contributions to the regulation of these technologies, among which the EU has gone the farthest with the adoption of the ,,Artificial intelligence Act'' (P9_TA(2024)0138). Within the framework of their powers, the aforementioned entities offered areas of application of AI and DLT, but also provided specific normative solutions either in the form of "technology in trade" or in the form of "technology for trade". Therefore, these technologies are found in sources of international trade law of different hierarchies, but also in legal documents that will be the basis for creating new normative solutions in the future. This paper will focus on the international trade aspects of these technologies by analyzing the work of UNCITRAL, UNESCO, WTO and EU in order to show the basics but also the trends in the international trade relations of AI and DLT.

Open access
International Arbitration and Investment Law
World Trade Organization Law
Original source
Jan 1, 2024·SSRN Electronic Journal
1 cites
The DAO Between the Nation State and the Network State

Filippo Zatti

The rapid advancement of digitization and decentralization is heralding a new era in social and economic organization. As nation-states grapple with the impact of (post-)globalization and technological innovation, increasing attention is being paid to blockchain technology's potential to enable the emergence of new governance structures, such as decentralized autonomous organizations (DAOs) and network states. This chapter analyzes whether DAOs could provide a viable framework for addressing the needs of future societies while maintaining fundamental principles such as democratic processes and the rule of law.

Open access
2 source records
International Arbitration and Investment Law
ICT Impact and Policies
Dispute Resolution and Class Actions
Original source
Dec 19, 2023·Indonesian Law Journal
3 cites
THE FUTURE OF INTELLECTUAL PROPERTY PROTECTION: ISSUES AGAINST THE METAVERSE AND NON-FUNGIBLE TOKENS (NFTs)

Habbi Firlana, Pascalis Dani Kriti Wibowo

Intellectual property protection is a right that must be granted by the state to the holder of a work and the increasing number of intellectual property rights problems such as theft of a work or indirect theft, for example, plagiarism, means that it is very necessary to protect every work produced. This research uses a literature review. This research aims to provide information on the results of analyses related to the protection of intellectual property which has caused many problems related to intellectual property. The results of this research show that the blockchain system must also be utilized by the Indonesian Government to become a central database for virtual intellectual property and public domain collections. Legal protection in Indonesia still needs to be strengthened on the law enforcement side to provide legal certainty for stakeholders so that public confidence arises in registering their intellectual property. Legal protection in Indonesia still needs to be strengthened on the law enforcement side to provide legal certainty for stakeholders so that public confidence arises in registering their intellectual property.

Open access
International Arbitration and Investment Law
Original source
Oct 1, 2023·Journal of European Competition Law & Practice
3 cites
Re-Prioritising Referrals under Article 22 EUMR: Consequences for Third Parties and Mutual Trust between Competition Authorities

Katalin Cseres

Merger regulation is a fundamental instrument by which competition authorities control the structure of an industry. Despite its relevance, the EU Treaties contain no rules on merger control. From the Commission’s first initiative to regulate concentrations at the EU level in 1966, it has taken more than 20 years of negotiations between the Member States and the European Commission to reach an agreement on EU legislation to control concentrations. The history of the European Merger Regulation reflects differing national views of the Member States and EU institutions on the necessity or the rejection of controlling concentrations and positions its legislative process and the various contradicting national interests of Member States against the apps and flows of EU integration throughout the 1960s, 70s, and 80s. At the core of this ‘protracted trench warfare’2 lied the delegation of enforcement powers to an already-powerful Commission, which the Member States initially opposed to. Capturing or delegating jurisdiction, hence, the distribution of administrative and enforcement authority between the national and EU authorities remained one of the most contentious issues during the bitterly fought negotiations. A similarly fierce and heated discussion on the distribution of administrative and enforcement powers across national authorities and the EU Commission has surfaced since the adoption of the European Commission Guidance on the referral mechanism under Article 22 in 20213 and the General Court’s judgment in Illumina/GRAIL4 and the Commission’s prohibition decision in 2022. Article 22 is a corrective mechanism of the Merger Regulation, which allows for one or more Member States to request the Commission to examine, for those Member States, any concentration that does not have an EU dimension but affects trade between Member States and threatens to significantly affect competition within the territory of the Member State or States making the request. This article assesses the distribution of enforcement powers across national authorities and the European Commission, in light of the Commission’s Guidance on the referral mechanisms under Article 22 in 2021 and the General Court’s judgment in Illumina/GRAIL1 and the Commission’s prohibition decision in 2022. The Article shows how the issue of delegation of enforcement powers between the Member States and the EU institutions has always been at the heart of the negotiation processes of the Merger Regulation, and though implemented through compromises, such as Article 22, this question may not have been entirely resolved. The article critically analyses two specific consequences of the way the Commission re-prioritised cases eligible for Article 22 referrals: the consequences of the Commission’s new policy for third parties and the principles of effective competition law enforcement including the principle of loyal cooperation and mutual trust. Born out of a political compromise, Article 22 of the European Merger Regulation has been characterised as a ‘late bi-product of the negotiations to create a merger control regime’ at the EU level and as ‘a mechanism riddled with gaps and uncertainties’. 5 After more than 20 years of low enforcement and largely decreased relevance of what has been initially nicknamed the ‘Dutch-clause’, these gaps and uncertainties are at the centre of extensive and heated debates about the way the Commission has announced to revigorate this enforcement mechanism. In this article, I first show how the issue of delegation of enforcement powers between the Member States and the EU institutions have always been at the heart of the (difficult) negotiation processes of the Merger Regulation, and though implemented through compromises, such as Article 22, this question may not have been entirely resolved. Second, I analyse the underlying rationale and development of the enforcement mechanism of Article 22 from the adoption of the first Merger Regulation in 1989 until the recently adopted Guidance of the Commission and the Court’s judgment in Illumina/GRAIL to provide a deeper interpretation of the referral mechanism laid down in Article 22 and to show the policy shift from discouraging to encouraging referrals. Third, I discuss two specific aspects of the new policy as enshrined in the 2021 Guidance and the mechanism currently underlying referrals under Article 22 EUMR that have so far been overlooked: the consequences of the radical re-prioritisation of referrals and the Commission’s policy under Article 22 for third parties and for the effective functioning of the (close) cooperation between the Commission and the NCAs. I argue that on the one hand, the Commission’s re-prioritisation of cases eligible for Article 22 referrals has re-written and largely eliminated procedural rights for third parties as established in the EU Merger Regulation. On the other hand, by re-activating the referral mechanism of Article 22, the Commission needs to reconsider the mechanism currently enshrined under Article 22. These procedures and mechanisms follow the enforcement logic and jurisdictional principles laid down in Regulation 1/2003, and accordingly, the same principles of effective enforcement including the General Court’s recent Sped-Pro6 ruling should to these the principle of loyal cooperation and mutual trust. The of merger control in the EU not a has been one with the between Member States and EU institutions at of the integration The regulation of has first been by the of in for the and the implemented by the of remained on merger control. In the years the the Member States national merger control In the in those years that and Member States or of of as a for national to the of and the of merger control rules in the Treaties the of the of as a law that out the and but not down a agreement to the European Commission to a merger and an authority within the jurisdictional of the EU The first of this its on the of in the the Commission its that merger should of the Commission’s as an of This the first of what the Commission as the between its competition authority and merger control. The Commission that it to the powers to it by Regulation at that extensive enforcement powers to for of the Commission by it as a In the European Commission, out other of its and the it on the in the the a policy and the Commission not to for the controlling and to authority of to the it to the from a that authority on and one through as authority to to and to the of for the of the European as a of throughout the and the about the of Member States no to in any during the The in the history of merger control the Commission’s decision in it and an interpretation of Article Article In its on the Commission that Article it to in cases of concentrations which from a of and which The Commission, by its authority and hence, a merger control on Article In to these the Commission the of legislative The first for a Regulation by the Commission in in which it to its authority to through legislative The of merger control the reach of its control against which a merger to with the on principles on on and the of which the Commission The fierce in the on various from Member The two most issues the of the regulation and the distribution of administrative and enforcement authority between the national and and the opposed the and of its that the of merger rules the to national or opposed of a to to the in of the as it the that its merger but it to authority to the such as the no legislation to low as no national at of the negotiations the between the European and enforcement powers to those by Regulation for the enforcement of and and authority to the Commission opposed by Member States, such as and that the Commission that a the legislation After this first it years to reach agreement on the merger control and in the largely and the and across these remained the issues of and administrative authority to on The Commission’s for a merger regulation in the and to the new and political of the that The to the in the the Commission’s merger control a merger control to the of a a in Commission The to create the European of the Merger Regulation not in the on the two to in of the EU and as the and and the most of the that by the than the referrals that in its The of at the in to the of the by the of a it for the to with the merger for the to the regulation of more it the relevance of competition policy to the that the rationale the of this new European the to more competition within the this of competition at the same The for a European competition policy as as the that the European Commission for and The Merger Regulation on 1989 and as Regulation The Regulation has been in and the new Regulation as Regulation From its in the Regulation laid down rules for for controlling between Member States and the EU Commission by to In cases these are the merger has a and within the of the Commission and Member States not national competition the Commission has no under the Merger Regulation the concentration does not have a This principle a of a a as in Article of the Regulation, and this merger has a the Regulation The which remained throughout the the to provide and between the and that of the Member This of to between the EU and national to Article of the Regulation, the of powers is on the principle of this of is to corrective mechanisms and the in Article of the Regulation and referrals and the Member States under and 22. In the the article on Article 22, the Article of Regulation out for referral of a concentration from a Member State to the the referral request by one or more Member the that is the of that request the of concentration out in Article of that regulation the for a European dimension laid down in Article of that the concentration affect trade between Member the concentration to significantly affect competition within the territory of the Member State or States that the referral request. to the third a concentration this to the that it is to have on the of trade between Member to the a Member State or States in to on a is a that the may have a on competition and that it may in the of of such a but to the of a In the of Regulation the Commission to of the the Member In for to than it the Commission a Member State to a merger on a within a Member This with one for those that the remained The Article 22 Member States to the Commission to that the This in cases national competition merger such as the in this of or than those at the European level or national authorities from Article 22 a ‘late of the to the of an EU level merger control Article 22 out of a compromise, which such as the to the mechanism in to as an and hence, no to the way Article 22 in the adoption of the Regulation, most Member States have adopted national merger control and the for Article 22 has been enforcement under Article In of Article 22 has been a cases as of it has been that its to to and the Commission to that the of merger control as a and the the Commission, by making of its in and Article 22, a of discouraging referrals from to the In its the Commission has out that the for of Article 22 in its to the that most Member States adopted legislation on merger control the Commission the of Article but has to to for the that with the adoption of the new Merger Regulation in the of Article 22 the of on trade between Member States as a for one or more Member States to to request the Commission to a concentration that does not have an EU dimension and threatens to significantly affect competition within the territory of the Member making the Second, Article the the Commission the to one or Member States that a concentration the out in Article and the Commission may those Member to a referral through a In the the Commission in with and third parties the of powers between the Commission and national competition the Commission that the the and jurisdictional of merger control in the the of cases between the Commission and the Member and in most been effective in cases that have a relevance from those with a national in about the to the in light of the Commission’s of that of but to the the Commission similarly that no for In the Commission to on its of on of for in the and that have but to the or in the and hence, In the Commission adopted a Guidance which its policy discouraging Article 22 referrals. on to discuss the Guidance more a on the and referral request that the Commission in After an the Commission the between and the Commission Member States by an in with Article of the Regulation for A referral request by by the and to the of by under the EU Merger Regulation. The not the of the EU Merger Regulation, and not in any Member but the for referral under Article 22 of the EU Merger Regulation. The Commission that the affect trade within the and to significantly affect competition within the territory of the Member States that the referral request and that a referral is not in its the Commission decision the referral in by that the Commission not a referral request from an in a merger law but the does not the for that the Commission’s interpretation to the principle and the principles of and On the General these and an extensive of the and of Article 22 In its the the Guidance as a which the adoption of the Merger Regulation and hence, not to the interpretation of that regulation to the of the the that Article 22 of Regulation at making the referral more and effective in to that a concentration with by the authority to analyse its to effective of the principles of and the as as to the The General that from the the legislative and the of Article 22 of the Merger Regulation, as as from the Commission’s enforcement it that Article 22 is to referral may for a concentration that does not within the of the merger control rules of the Member State that its In the Court’s interpretation of Article 22, the Commission may a concentration that threatens significantly to affect competition within the territory of a Member State and affects trade between Member States, which not to any by the national authorities or by the Commission and hence, an that by the Member In that it is to at the EU in of Regulation Article 22 an effective corrective mechanism in the light of the principle of by the interests of the Member In light of that principle and in with of that Regulation, a with by the most by the principle of of should to competition authority in the is the more for with a to the specific of the as as the and to the should to the of any on competition from the the referral of cases of aspects of the of the principle of including the in a and the of with to to to or to a the Commission and Member States should in the to effective of competition in by the The General that in which concentrations are not but to the Member State not within the of that or no such within Article 22 Article of Regulation a Member of the of its national merger control to to the Commission concentrations that not the in Article of that Regulation, but that may have the General that referral mechanisms are an instrument to control in a on of its is not of concentrations that at the European mechanisms as by the in of Regulation a of the Commission that on it the to the of that which is to the control of concentrations significantly to effective competition in the The 2021 Guidance is an of the Commission’s administrative it policy to the General in Commission a in control competition in with to referrals under merger the that the Commission has as to or not to a to of the on the Commission and Member States a of in to cases within or to to with cases not within to Article 22. The Guidance these and procedural on the of Article 22. The Commission’s to the of Article 22 EUMR has been that the Commission is its a for Member States merger control legislation in to the of the in merger control more than years and that the Guidance is ‘a law that the Regulation or at the of the In the I discuss two specific aspects of the Guidance and the mechanism currently underlying referrals under Article 22 that have so far been I argue with the adoption of the the Commission has not significantly re-prioritised cases eligible for Article 22 referrals and its established policy on discouraging but it has re-written the procedural rights for third parties as established in the Merger Regulation. administrative authorities to with principles of EU law and principles of that of powers by administrative Second, by re-activating the referral mechanism of Article 22, the Commission should reconsider the enforcement currently enshrined under Article 22 This on the of and between the Commission and the to Article of the Merger Regulation. and between the Commission and the and between the are in the referral out in the Merger Regulation. and on the of to the Merger Regulation, a of in these procedures and mechanisms the of cooperation under Regulation and follow the enforcement logic and jurisdictional principles laid down in that Regulation. the of the of on trade between Member States and a cooperation between and the Commission under Article 22 is a of such the same principles of effective enforcement as established by the European and recently by the General in its ruling should to this such as the principle of loyal cooperation and mutual trust. In with the structure of these the EU have characterised the procedural rights of third a to to the This as a to in the administrative from the to as a of the of the The Commission’s enforcement is but not to the administrative procedures to and as laid down under Regulation In merger parties to to the Commission for and may the Commission’s and and the Commission may the procedural and of third parties in these procedures as in Regulation third parties have a in the to the Commission’s by of to for to Article of the Merger Regulation, and provide and for the of a may third parties for to discuss and specific issues to Article Regulation third parties a to to Article of the Commission’s Regulation third parties are or including and are to a such as the concentration or by and of the administrative or of the or the of Article that third parties may within a that has been by the to the by the third parties in the Commission may the to in a At the same as the has that procedural of third parties with that of the and of to in the first Article the by the concentration in the parties to the concentration for by the Commission, the specific laid down in those in to that rights of are in the of the administrative Article in to third since are to the of the the to by the Commission, that have so and have that have a for that the Commission in the of the in provide third parties that have a with a of the of in to to views on the Commission’s of the the Commission in the such third parties are to the of a a to to this does not the that have been to third parties are to for the of the to Regulation procedural rights of third parties are not as extensive as the rights to the in to rights of it is the in so far as show a third parties have a under Article of Regulation to have so these procedural rights are in with the procedures laid down under and provide procedural and rights to third the 2021 largely these procedural rights to and to to the of the and down to the to the Commission or the authorities of the Member States, and of a concentration in a for a referral under Article this does not any on the authorities of the Member States or on the Commission to any a by a third any by third parties in the referral is in of the and such a fundamental of and parties are not competition authorities in the functioning of The of third parties is on this of as provide that to an of the that the to issue a decision in with the of the the by the concentration in the parties to the concentration for by the Commission, in the of third parties not to have an in its the affect not always in a are to the of the which in a procedural with to as third parties under Article of the Regulation, the General in that that those may in does not the of its to The Commission Article of Regulation in which the of that in to cases in which a merger has on a the of the of Article of Regulation as of the Commission the interests of the and The that Article which has the same as Article taken in and other EU and Article of the of of the European that EU a level of in administrative procedures is an of and that the of the and the as a to third parties are the to the decision of the competition or that to the of the These procedural have been by the Guidance in the referral making for third parties to a to the Commission in an is to so as one of the of Article 22 is that the concentration affect trade between Member This is an jurisdictional in the enforcement of the Merger Regulation, as other mechanisms on the in Article in of the a concentration the of on trade between Member States laid down in Article 22 it is to have on the of trade between Member this is in the to the Commission’s on the on trade in and the referral mechanism on and between the Commission and the and cooperation and to the European for and under Regulation 1/2003, the and the Commission a of in under the Merger Regulation. At the same the referral mechanism of Article 22 on the of to The Commission Member States to to the Commission as the most authority to the but it to is the of the Member States to a to the This the Guidance cooperation between and the Commission, it a of to the to a to a to the Commission, third parties more than the Commission as a with the jurisdictional and enforcement cooperation of Regulation the question the same principles of effective enforcement as the underlying Regulation should to Article 22 referrals. those and in light of the enforcement of and and the principle of procedural and the to a of fundamental under EU Member States powers to the of and The principle of which is a of Regulation and Member States not to the of EU law in or that the rules which or not the effective of and The principle of a to in EU law competition and other authorities as in the competition to to that is by is an of political competition is Member States should from legislative or other that the of its The have on various the Member States have on the of the principle of which the of national enforcement so that Member States to the of EU law within the Second, of cooperation with the Commission and other which is on and and on the that Member States that enforcement but the of as a for The on the of mutual and in which other in making of and powers in to This has been by the General in competition law in its judgment the of law issues to taken a national competition authority is of competition law and third In its a principles of between the Commission and the the General that with the fundamental of Article to the competition law enforcement mechanisms under and In this the General for the first established a between in the of a Member State and the of its competition authority to and enforcement under EU law and a The General issues of of law as an of effective competition law enforcement and the principles between the Commission and under the enforcement of Regulation to its law in the of the European the General as in the of and the cooperation between the Commission, the competition authorities of the Member States, and the national for the of and is on the principles of mutual mutual and loyal of those of those authorities and that other authorities and law for more the fundamental rights by that to the General for the of which competition authority is the to a the Commission to with the of the of law as a to the the of the rights and the Commission’s are this judgment the Commission to its decision to at of to by national authorities by of law The judgment that the Commission of the of of law on and in this the a new that the Commission, a for of EU to that the national authorities are of the rights of the The judgment is it a of and between the and the Commission and cooperation on mutual mutual and with these principles underlying enforcement and cooperation under Regulation and the General Court’s judgment in and on the of the between the principles underlying Article 22 referrals and I argue that the Commission should of the of effective competition law enforcement and of law referrals are an to the Guidance in a way that referrals not on the and of to The of of with the of of authorities the the of cooperation between Member States and the Commission and that the should with by the This is more so the that the European Commission and have as the of as as rights to and in effective enforcement of competition law not is for competition within the but of effective as laid down in Article of the of to and in the competition This the a Member State from its merger control effective competition in the Member State and in the This is the same as in the years of the Merger Regulation, Member States no merger that the adoption of the This is the the and such the and of merger to control in a way that it does not in to competition in the and to effective of concentrations with a of on the structure of competition in the and to effective competition in the or in a of In in that of a merger control to gaps in the of against of competition in to that ‘a in has in recent years in the and under competition of of for in the of or this the Commission has its enforcement mechanism enshrined in Article 22 of the Merger Regulation. the Commission as an administrative to the of to with powers in to and and EU policy including competition are to and effective regulation and procedures with a of on the of the administrative as the and the European Commission in is policy these not but and administrative and and on of procedural and This article that third in administrative procedures is a of and that the of competition the procedural and procedural rights of third parties in the referral the powers of the Commission and of the This the Commission’s referral with the of in the of a of and procedural rules that the of third parties to the referral to those to in the rights of the of that that may have on should by administrative law as a to control the of the adoption of the 2021 Guidance of encouraging referrals from Member States under Article 22, which of merger control the Commission has not to for procedural but and views of Member States and the EU institutions on which in national national or at the of national and the of effective the and development of Article 22 and its this article that the of Article 22 referrals the cooperation mechanisms and its procedural as it has under the enforcement of Regulation 1/2003, cooperation is a fundamental of effective competition law the Commission should not the in and the new it to administrative but on the in Member States that the effective of competition in the The General Court’s recent judgment in is in the of effective referrals and and effective enforcement of competition between Member States and the The jurisdictional in merger control between the Commission and the Member States effective and Member States to the and and the and its such as an competition in the

Open access
International Arbitration and Investment Law
European and International Law Studies
Conflict of Laws and Jurisdiction
Original source
Jan 1, 2023·SSRN Electronic Journal
4 cites
Decentralized Autonomous Organizations (DAOs) Before State Courts. How Can Private International Law Keep Up With Global Digital Entities?

Florence Guillaume

This paper examines civil and commercial disputes involving Decentralized Autonomous Organizations (DAOs) and the complex questions of private international law that arise. The legal capacity of a DAO to be a plaintiff or defendant in court varies across jurisdictions, highlighting the need to determine the applicable law to a DAO. A distinction must be made between different types of DAOs. There are currently a few jurisdictions, notably in the United States, that have enacted DAO legislation defining a legal status for such entities. Those regulated DAOs are governed by both computer code and company law. In other jurisdictions, existing company structures can be used to offer a legal wrapper to DAOs. However, the vast majority of DAOs currently in existence are constituted and solely governed by code, posing challenges in bringing them before a state court. The paper explores recent case law and the difficulties in identifying the appropriate party to sue when pursuing a DAO. Using Swiss law as a basis, it examines the qualification of DAOs under private international law and the challenges of anchoring a global digital entity to a specific jurisdiction. The article illustrates these challenges through three types of disputes: governance, contractual, and tort-related. Determining jurisdiction over a DAO-related dispute requires applying private international law rules. Although the paper assumes Swiss courts for convenience, the reasoning can be applied to different legal systems due to the similarities in conflict of jurisdiction rules. However, challenges persist even if a court has jurisdiction and renders a decision, as enforcement may prove difficult, especially on-chain. Additionally, initiating legal proceedings against a DAO presents issues with serving court documents. DAOs offer opportunities for innovative electronic methods of document service, but specific requirements and restrictions exist for international service of documents. Practical difficulties may arise, making it impractical or unattainable to serve court documents on the defendant. The analysis concludes that state courts currently struggle to ensure reliable access to justice in disputes involving DAOs. As an alternative to state courts, opting for Alternative Dispute Resolution (ADR) mechanisms, such as Blockchain-based Dispute Resolution (BDR), can offer a simpler and more efficient solution depending on circumstances. In any case, entrusting dispute resolution to a BDR mechanism avoids the complexities associated with state court procedures.

Open access
2 source records
International Arbitration and Investment Law
Conflict of Laws and Jurisdiction
Corporate Governance and Law
Original source
Jul 1, 2022·London Review of International Law
1 cites
International law in the age of digital media: Reflections on history, the neoliberal communication sphere, and race

Barrie Sander

In his new monograph, Informed Publics, Media, and International Law, Daniel Joyce sets out to explore the role of the media both as an object of international legal regulation and as an influence on international law’s development and structure.1 Given the obvious connections between the media and international law, one might have expected the topic to have already garnered extensive interest within the existing literature. Yet, as Joyce observes at the outset, ‘[f]or all its ubiquity and power, the media has to date been the subject of surprisingly limited attention within international legal scholarship’.2 In this context, the publication of Joyce’s text may be viewed as part of a recent wave of literature that signals growing interest in the subject amongst international legal scholars, whether due to rising concerns over the use of international law in public debates,3 or as a result of the exponential growth of new channels of communication, most notably digital media platforms.4 In tackling the multi-dimensional relationship between the media and international law, Joyce’s approach is historical and critical, illustrating both ‘the resilience of existing international law frameworks, but also their significant silences’.5 The historical perspective is particularly valuable in surfacing interesting continuities between present-day controversies and earlier eras. For example, Joyce reveals how contemporary concerns about the relationship between international law, populism, and social media,6 find echoes in a range of formative debates about the relationship between international law, public opinion, and the press in the early twentieth century.7 The drawing of historical parallels is particularly important given the fast pace of developments in the sphere of communication in the digital age. In particular, as the notion of Web 3.0 (or Web3)—the much-hyped third generation of the Internet premised on ‘decentralised’ technologies, touted to follow static webpages (Web 1.0) and social media and user-generated content (Web 2.0)—begins to enter the public consciousness, adopting a historical perspective may help nurture what Elizabeth Renieris recently termed an outlook of ‘informed skepticism’.8 As Renieris explains, similar to its predecessors, ‘Web3 is imagined as being apolitical, open, decentralized and inclusive’, seemingly oblivious to the fact that ‘[t]his ethos—characterised by free speech absolutism and free market ideals—has enabled all manner of online harms, including rampant mis- and disinformation, racism, discrimination, hate speech and harassment, concentrations of power, toxic business models and limited accountability’.9 In this context, Joyce’s text is particularly useful in situating the shifting contemporary communication sphere along a broader historical trajectory, tracing the neoliberalisation of public communication across different time-periods and settings, and shining a spotlight on the role performed by international law in the process. Beyond its critical and historical orientation, at the centre of Joyce’s text is the concept of ‘informed publics’, characterised as ‘a more inclusive and messier picture of the social and connective tissue of international law’ than the notion of ‘international community’.10 If claims made in the name of the latter are often merely ‘attempts to translate the particular into a language of self-serving universalism’,11 Joyce advances the notion of ‘informed publics’ as ‘a model of international civil society which allows for greater variety of forms of association’, both by ‘contest[ing] the state-centrism of international law and better reflect[ing] a system which involves not a single participatory democracy but a range of regional, domestic and local polities’.12 For Joyce, ‘international law depends on informed global publics to function and to address the complex global problems which we face’.13 In this way, the concept of ‘informed publics’ emerges as a ‘normative goal’ for international law, one which ‘remains critical to any future conception and realisation of a multilateral system of global governance’.14 It is the concept of ‘informed publics’ that draws into view the dual inquiry at the centre of Joyce’s research:15 first, the role of international law in regulating the media, including new forms of digital media; and second, the reliance of international law on the media in communicating its objectives and norms as well as in its functioning as a system. In reflecting on Joyce’s work, this review follows the book’s structure, with a particular focus on the text’s discussion of the relationship between digital media and international law. In the first half of the book, Joyce examines a range of international law frameworks applicable to the media which adhere to different regulatory models—each recognising and foregrounding certain values and interests to the marginalisation and exclusion of others. In Chapter 2, Joyce examines the regulatory vision of free publics, encompassing the ways in which human rights law (particularly freedom of expression) has sought to protect media freedom from State intervention, as well as how international trade law has sought to ensure free markets for the global media economy.16 Both areas of law emphasise media freedom—with human rights law focused on protecting the media’s societal watchdog function, and trade law focused on deregulation and market access.17 Yet, as Joyce explains, this emphasis comes at the expense of addressing ‘the power of the media itself and its own connections with violence and the abuse of rights’.18 In Chapter 3, Joyce turns to the regulatory model of endangered publics, encompassing the ways in which human rights law (concerning incitement, hate speech, and propaganda), international criminal law (concerning atrocity speech), and international humanitarian law (concerning media activities in armed conflict) address the connections between the media and violence.19 While these areas of law counter the reductively positive image of the media that underpins the regulatory vision of free publics, Joyce observes that they nonetheless ‘configure the dangers of media power as being exceptional rather than structural’ and thereby contribute to ‘a failure to connect media violence with its economic and political power’.20 Finally, in Chapter 4, Joyce discusses the regulatory model of digital publics, encompassing forms of Internet, data, and platform governance, which are characterised by ‘an absence of international law’ and an investment of faith in the promise of ‘self-regulation, market-driven innovation and techno-libertarianism’.21 Joyce suggests that while international law and the media are often depicted as being ‘existentially threatened by technological disruption’, at least part of this ‘crisis’ concerns ‘the ongoing failure of international legal frameworks to address the rise of information capitalism in the form of digital media monopoly’.22 Across these chapters, Joyce offers a compelling analysis of the international regulatory landscape applicable to the media, traversing a diversity of contexts to critically surface both the blind spots and biases identifiable within a range of fields of international law. In an era of specialisation, where scholarship is becoming increasingly siloed, Joyce’s ability to bring diverse fields of international law into conversation with one another is particularly valuable. At the same time, by adopting such a broad perspective some level of detail and nuance is inevitably sacrificed. In exploring the relationship between international law and new forms of digital media in particular, Joyce’s text unveils many of the challenges that have arisen in attempting to reign in the power of today’s leading digital media companies. However, to some extent, I would argue, Joyce understates the significance of both the state and the law in both enabling the neoliberalisation of the contemporary digital communication sphere and in continuing to legitimate various repressive practices undertaken within it. Whilst acknowledging that the Internet ‘evolved in collaborations between governments, the military and academic institutions’,23 the role of both the state and legal frameworks in the Internet’s historical trajectory remains somewhat marginalised in Joyce’s account. The influence of the state on the shape of the contemporary online environment is well documented. Monika Zalnieriute, for example, discusses the dominance of the ‘US Information-Industrial-Complex’, which ‘catalysed the rapid growth of information and communication technologies within the global economy, while firmly embedding US strategic interests and companies at the heart of the current neoliberal regime’.24 Support from the US government took at least two forms. First, the US government provided significant amounts of funding and awarded a range of procurement contracts to US technology companies—a fact that not only undercuts the neoliberal myth that private wealth accumulates because free markets are kept distinct from public expenditure, but also provides important context for the Edward Snowden disclosures which revealed close ties between the US National Security Agency and a number of US technology giants.25 Second, the US government also supported its largest US technology companies by promoting an ‘Internet Freedom’ agenda abroad, premised on ‘globally “normalised” strong legal protections for intellectual property rights, advertising-based consumerism and the commodification of information and personal data’.26 And it is here that both domestic and international law become part of the story of the neoliberalisation of the contemporary online environment. As the works of Julie Cohen and Amy Kapczynski, amongst others, have demonstrated, ‘rising platform power, monopoly power, and the power that technology can give capital over workers and governments over the governed 
 are mediated at every moment by law’.27 At the domestic level, fields such as contract, trade-secrecy, intermediary immunities, privacy, and the First Amendment helped anchor the rising power of online platforms, while at the international level, trade agreements have prohibited the restriction of cross-border online information flows and forbidden data localization rules.28 As Kapczynski argues, ‘a wave has rippled through our law 
 [which], intertwined with the architecture of digital networks, has enabled the creation of the vast new firms that wield new forms of surveillance and algorithmic power, 
 [and] delivered us a form of neoliberal capitalism that is inclined toward monopoly, concentrated power, and inequality’.29 By placing emphasis on the absence of international law in the digital domain,30 Joyce’s account understates some of the ways in which both domestic and international law have helped shape the neoliberal communication sphere that characterises the contemporary online environment. Beyond shaping today’s online environment, international law also performs a role in legitimating certain repressive practices within it. Joyce’s account is alive to law’s legitimation function, particularly in the context of discussing the co-option of the vocabulary of human rights law by social media companies ‘not as binding legal norms, but as available ingredients to enable corporate self-regulation and marketing’, as well as ‘to minimise the damage to their reputations’.31 Yet, the legitimation function of international law extends beyond this corporate context. Consider, for example, the recent majority judgment of the Grand Chamber of the European Court of Human Rights in the bulk surveillance case of Big Brother Watch and Others v UK.32 The judgment endorsed the legality of bulk surveillance operations as in principle ‘valuable’ and of ‘vital importance’ for states seeking to identify threats to their national security,33 provided such programmes contain sufficient ‘guarantees against abuse’ and are subject to a set of ‘end-to-end safeguards’.34 By adopting this approach, the majority judgment adhered to a form of ‘procedural fetishism’,35 which has been characterised as nothing less than ‘a grand, definitive normalization of mass surveillance[,] by a virtually unanimous Grand Chamber[,] for decades to come’.36 In his concluding remarks, Joyce suggests that ‘it is important to reconsider the value and resilience of existing international media law frameworks including, most significantly, the human rights model, but also to be realistic about the failures and problems associated with that system’.37 Yet, while Joyce acknowledges the limits of the vocabulary of human rights law in general terms—including how the human rights system ‘struggles with controlling private power, individuates and simplifies collective and highly complex issues, and often underplays their structural dimension’38—a more detailed exploration of the ways in which human rights law has legitimated and struggled to reign in particular forms of private and state power in the digital domain would have helped prepare the ground for assessing the extent to which it is equipped to address the accountability deficits associated with the contemporary online environment.39 In the second half of the book, Joyce turns to examine how the media is coming to shape various dimensions of international law. In Chapter 5, Joyce explores publicity as a technique utilised by international courts and actors to claim legitimacy and signal their authority. Joyce focuses in particular on the fields of international criminal law and human rights law, observing how ‘mediatized trials have public relations benefits, but also present the now familiar dangers of media spectacle’, whilst ‘human rights witnessing promises connection but can also deliver commodification and simplification’.40 Reflecting on these tensions, Joyce concludes that while adopting media forms and engaging in public relations may be understood as ‘the international legal system 
 responding to demands for greater transparency, accountability and participation’, ultimately ‘publicity cannot act as a substitute for informed publics who are so often kept at a distance from the levers of institutional power and influence’.41 In Chapter 6, Joyce considers the broader critique of the communicative capitalism that underpins international law’s reliance on the media and its increasingly digitalised form. To this end, Joyce examines ‘not only the media’s role in bringing issues to public consciousness, but also its implication in the preservation of silences and the maintenance of obsessions and anxieties’,42 and reveals the ways in which the growing reliance of international actors on digital media platforms ‘further entangles the field with neoliberal ideologies embedded within the infrastructure of Silicon Valley’.43 The result, Joyce concludes, is that ‘publicity promises participation, but delivers digital media monopoly, corporate “values” as structuring norms and increasing private power on the international plane’.44 Joyce’s analysis in these chapters is again impressive, drawing on a diversity of disciplinary perspectives ranging from political theory to communications studies to reveal how the turn by international actors to mediated techniques of publicity has produced ‘effects of both visibility (for one or a group of victims or a theme) and invisibility (for other forgotten victims, contextual analysis and different or competing claims and causes)’,45 whilst masking and facilitating ‘the broader privatisation of the public sphere’.46 Where the text might have delved deeper, however, is in surfacing the ways in which the contemporary online environment enables the reproduction of inequalities, for example along gender and racial lines. In discussing mass atrocities in Myanmar, for example, Joyce points to the failure of Facebook to prevent its platform being used as a tool to incite violence against the Rohingya community.47 However, what is omitted from Joyce’s account is any exploration of the reasons behind Facebook’s passivity in this context.48 Reflecting on the contrast between Facebook’s de-platforming of Donald Trump following the US Capitol riots and its general passivity in Myanmar, Rebecca Hamilton has reflected upon ‘the role that economic and political power—coupled with cultural affinity, and distributed unevenly across and within States—plays in the decisions of major [social media companies] about what content stays on their platforms’.49 According to Hamilton, global inequities behind how content is moderated on digital platforms are partially a reflection of capitalism, calculated in the advertiser revenue that a platform derives from an American user compared to a user in Myanmar, and partially a reflection of unevenly distributed political power, with ‘years of local activism, coupled with international reporting and a United Nations Commission of Inquiry [being required] to finally get Facebook to take the kind of de-platforming action [in Myanmar that] it did in the United States’.50 But another part of the story concerns systemic racial bias. As Hamilton notes, major social media companies ‘continue to default to the cultural assumptions and political and economic incentives held by their predominantly white American male founders’.51 This ongoing ‘diversity crisis’ in the digital technology sector is significant since, as UN Special Rapporteur on contemporary forms of racism, E Tendayi Achiume, recently observed, ‘technology 
 that disproportionately excludes women, racial, ethnic and other minorities is likely to reproduce these inequalities when it is deployed’.52 Joyce also critically discusses ‘platform humanitarianism’, encompassing the turn within the human rights movement towards ‘commodified forms of advocacy, fundraising and competition for attention and power between NGOs’, initially drawing on the emergence of global media, but today increasingly reliant on digital media platforms ‘to communicate its messages, seek publicity and engage in digital witnessing in the attempt to capture audiences motivated by humanitarian concerns’.53 One example that Joyce explores in this context is the notorious Kony 2012 campaign, in which an organisation called Invisible Children distributed a video across various digital media platforms calling for the capture and arrest of the leader of the Lord’s Resistance Army, Joseph Kony, by the end of 2012.54 As Joyce notes, the aim of the video was ‘to engage the American people to place on their government to the of military in to the in its to capture In this way, the video sought to a by the International Court into a in to his Joyce the Kony 2012 for the of the political in and to its whilst also to the broader that the focus of such may attention from social in the Yet, as the of has recently a to this story is how the a example of by as ‘the of social and economic value from the racial of another only is the Kony 2012 video with racial but by the US of the may also be within a broader historical in which international law has performed a role in the of value from the in international such as the or and military as For the of this form of global is the of and the of form of between the wealth and the of While Joyce acknowledges the that media may audiences and publics from for the of the racial dimensions of digital are at but not In Informed Publics, Daniel Joyce has made a valuable towards the complex and diverse connections between international law and the the end of the book, Joyce observes its ‘the media is not given the significance or in international legal which it has in other such as international political and social It is that with the publication of Joyce’s book, this to at a when international actors are to on the future regulation and use of digital media platforms, they would well to on the critical and historical in this The is to the and in the of International discussion on Daniel Joyce’s Informed Publics, and International Law, as well as the for their are the

Open access
International Law and Human Rights
International Arbitration and Investment Law
World Trade Organization Law
Original source
Mar 3, 2022·The Journal of World Energy Law & Business
8 cites
Electronic Alternative Dispute Resolution, smart contracts and equity in the energy sector

Zeenat Beebeejaun, Alessio Faccia

Abstract The intrinsic complex nature of Contracts in the Energy sector leads to frequent international disputes. The complexity is generated by (i) the involvement of multiple stakeholders with potentially conflicting interests (Multinational Companies, State-Owned Companies, Host States and their citizens); (ii) transnational jurisdictions divergence (local laws, investor’s country laws, international practices and regulations); and (iii) changes in the laws and regulations over time (long-term nature of Energy contracts). Therefore, not surprisingly, traditional litigation in the Energy sector is often replaced with Alternative Dispute Resolution (ADR) through the recurrent application of Arbitration clauses. This article aims to improve dispute management in the Energy sector by encouraging best ADR practices. Modelling and Conceptual research approaches are adopted to encourage the introduction of the smart contract. The analyses triggered the drafting of a model for contractual automation. Recurring top clauses are mapped and associated with Equity solutions. Moreover, a comprehensive, efficient and feasible ‘Electronic ADR’ framework is shaped to prevent (or automatically settle) disputes in the Energy sector.

Open access
International Arbitration and Investment Law
Corporate Governance and Law
Dispute Resolution and Class Actions
Original source
Jan 1, 2022·SSRN Electronic Journal
11 cites
Blockchain Dispute Resolution for Decentralized Autonomous Organizations: The Rise of Decentralized Autonomous Justice

Florence Guillaume, Sven Riva

For the past twenty years, the use of the Internet has facilitated international commercial relations between people who do not know each other and who are geographically distant. Disputes resulting from e-commerce have undermined the supremacy of state courts, which have proved unable to provide an appropriate response to small claims arising in an international context and raising delicate questions as to jurisdiction and applicable law. The length, cost and complexity of the procedure, as well as the risk associated with the international enforcement of the judgment are deterrent factors that led e-commerce platforms to develop online dispute resolution (ODR). Thanks in part to the removal of intermediaries, the transfer of cryptocurrencies and other crypto assets using blockchain technology has further facilitated international commercial relations. The decentralised and distributed characteristics of blockchain technology and the pseudonymity of its transactions has led to a new economy growing independently from nation states. This technology has brought an additional degree of complication in the application of Private International Law (PIL) rules by removing the illusion that online transactions can be linked to the territory of a state. Smart contracts also allow the creation of digital entities that can enter into commercial relations. The first Decentralized Autonomous Organization (DAO) was the source of a resounding dispute between parties with diverging interests, which had to be urgently resolved without any access to state courts or a dispute resolution mechanism. This case revealed the risk of disputes in the blockchain environment and the resulting legal uncertainty, and led to the emergence of various models of blockchain dispute resolution (BDR) mechanisms inspired by the solutions developed in e-commerce. This chapter deals with the application of PIL rules to the resolution of disputes involving DAOs. The authors first analyse what is a DAO and whether DAOs legally qualify as companies. What is at stake is the legal personality of DAOs and their capacity to conduct legal proceedings. The authors then examine whether disputes involving DAOs may be brought before state courts. This analysis highlights the problems related to the location, pseudonymity, and uncertainty regarding the legal personality of the participants of the blockchain environment, which challenge the jurisdiction of state courts in case of a dispute. The authors then draw on the experience acquired in the field of e-commerce to examine the advisability of setting up alternative dispute resolution mechanisms available to the actors of the blockchain environment. Based on an analysis of existing BDR mechanisms, the authors examine whether and how BDRs are likely to avoid a denial of justice and bring legal certainty to disputes related to contractual relationships with DAOs formalised through smart contracts as well as disputes related to the governance of DAOs. The authors find that a BDR decision which can be directly enforced through smart contracts confers effective justice to the actors of the blockchain environment. Finally, the authors address the more delicate issue of the enforcement of a BDR decision on non-crypto assets. This approach shows that a type of justice based on crypto-economic incentives challenges the concept of fair justice. This could be an impediment to obtaining the assistance of state authorities for the enforcement of a BDR decision outside of the blockchain environment as this type of decision could be considered contrary to public policy. The analysis is mostly based on Swiss PIL and major PIL conventions. In this chapter, the authors outline the contours of a new private justice system designed to provide decentralised autonomous justice to the actors of the crypto economy.

Open access
2 source records
International Arbitration and Investment Law
Dispute Resolution and Class Actions
Conflict of Laws and Jurisdiction
Original source
Dec 1, 2021·Bulletin of Alfred Nobel University Series Law
3 cites
INTERNATIONAL MUNICIPAL LAW AS A FIELD OF INTERNATIONAL PUBLIC LAW: ON THE QUESTION OF THE FORMATION OF THE INDUSTRY

Mykhaylo O. Baymuratov, Boris Ia. Kofman

The article is devoted to the scientific and theoretical substantiation of the position on the formation of international municipal law as a field of modern international public law. In domestic jurisprudence, the topic is being studied for the first time. The authors connect the emergence of international municipal law with the processes of constitutionalization of international public law and the internationalization of the constitutional legal order of states. These processes were accompanied by the growth of international recognition of the institution of local self-government. First of all, through its international legal regulation and contextualization of topical aspects of the activities of local governments, taking into account their international activities. In particular, through the development and adoption of a number of international multilateral treaties and the preparation at the United Nations level of the draft World Charter of Local Self-Government. In the context of the internationalization of the constitutional legal order of countries in the field of urban law, significant processes of borrowing international legal standards of local selfgovernment by state constitutional law are indicated. Based on the analysis of international practice, a conclusion is made about the compliance of Ukrainian legislation with international standards. At the same time, recommendations are given for its improvement, in particular, for financing local governments, budgetary decentralization, limiting the competence of local state administrations, etc. The formation and development of the architecture of modern public international law, its institutional and structural system is usually associated with its sectoral construction, which is based on the definition of the subject of legal regulation and method of legal regulation. The emergence of a new subject of legal regulation in public international law, as an independent and autonomous legal system, is based on the actualization, emergence, activation, contextualization of cooperation in a new field of interstate cooperation, which in practice is determined by the emergence of a new object of international law. In this case, the methods of international legal regulation in public international law remain constant – either imperative or dispositive. However, today in the formation of new branches of public international law plays an important role trend that emerged during the formation of a new form of globalization – legal, which has such a nomenclature – the constitutionalization of public international law and the internationalization of constitutional order. In general, the national legislation of Ukraine meets world standards, but some legislative norms should be improved. First of all, this concerns the financing of the local state administrations, limiting the competence of local state administrations to the level of control functions and mediation between the local governments, the executive branch and the President. In addition, it makes sense to provide a mechanism for the implementation of the international legal standards for the subjects of Ukrainian local self-government.

Open access
International Law and Human Rights
War, Law, and Justice
International Arbitration and Investment Law
Original source
Dec 1, 2021·Journal of Social Philosophy
9 cites
The legitimacy of international courts: The challenge of diversity

Neus Torbisco‐Casals

The emergence of an international judicial system is often perceived as a cornerstone in the process of building a ‘global’ system of governance.1 Since the end of the Cold War, we have witnessed the rapid proliferation of international courts and tribunals (hereinafter ICs) and the progressive expansion of their scope of jurisdiction to areas as diverse as trade, the law of the sea, human rights, and international crimes (Katzenstein, 2014; Kingsbury, 2012). These ‘new-style’ ICs and quasi-judicial bodies (Alter, 2014, p. 68) allow for wider access from potential litigants, and they are more autonomous than their predecessors, operating often on a transnational rather than inter-state model (Keohane et al., 2000). In doing so, they transcend their function of mere dispute settlement mechanisms to become law making actors in their own right, with significant discretion to interpret international law (Besson, 2014, pp. 419–428). This development has been hailed as a major shift from an international system based on politics and power toward one governed by shared rules and principles under a genuine ‘global rule of law’. Cosmopolitan-minded scholars and advocates, who dispute the place that territorial borders and national identities should have in delimiting our fundamental rights and allocating public goods, rejoice about the gradual collapse of the divides between the domestic and the international. Yet with the growing independence and expansion of the mandate of international judicial systems, these mechanisms have attracted attention as to their legitimacy and accountability in relation to different stakeholders. The international judiciary is no longer seen as “the least dangerous branch.”2 For some critics, accepting the jurisdiction of ICs entails ceding national sovereignty to ‘foreign’ judicial powers, which have an increasing capacity to create new law. For others, the international judiciary in the absence of a global democratic constituency represents another imposition of Western values that remain alien to other cultures. Moreover, in the current political climate, institutions of global governance, including ICs, are confronted by growing reactionary populist movements that pit democracy against internationalism. To these movements, the turn toward transnational forms of governance, legality and adjudication is perceived as a democratic dysfunction and belittled as harmful to the preservation of the identity and autonomy of a (monolithic and nationalistic) view of the polity. Regional and international human rights bodies, and the International Criminal Court (ICC), are particular targets, insofar as they typically address how states should treat individuals on their own territory. They also tend to protect marginalized minorities against the majority's conception of the identity and values of the polity, and seek to impose rule of law constraints on the executive and legislative branches that often claim democratic support. Yet other ICs—especially in the area of trade—have also become the target of populist and sovereigntist leaders as they are seen to impose unjustified constraints on desired domestic policies. In light of such diverging approaches, it becomes ever more crucial to inquire into the foundations of international courts' legitimacy. To this end, a number of scholars have called for a ‘democratic’ re-conceptualization of the international judiciary (Bogdandy & Venzke, 2014; Grossman, 2013). This has generated attention to a broad range of elements, from appointment processes to procedural rules in order to guarantee judicial independence but also accountability to different stakeholders (Grossman, 2013; PĂ©rez, 2017), typically with a focus on specific types of courts (FĂžllesdal et al., 2014; Hayashi & Bailliet, 2017; Hennette-Vauchez, 2015). Yet, as I will argue, by reducing the so-called ‘legitimacy deficit’ to a problem of institutional factors and representation of ‘national’ constituencies, we might be overlooking a deeper dimension of the ‘diversity challenge’—one that emerges out of the need for and The this by an of the legitimacy of ICs that to some of the in the populist of ICs, in particular the between democracy and internationalism. The from human rights courts and international as these are the of as I seek to is also to other ICs with domestic political is the for dispute settlement mechanisms in international and law and to a also international such as the International Court of I by in more the of democracy and for the legitimacy of ICs and with the of which has been a an global and in a of populist movements ICs in more democratic shared and a model of domestic and international Yet, as in such for a turn toward a ‘democratic’ model of international adjudication have an of the democratic accountability of domestic courts in the for the they This is it to the of the judiciary with to and the representation of has been in some and the of such of a particular domestic to some of the toward the the advocates, and in particular a of the of might and that might a of in international as a for the legitimacy of courts and increasing the of judicial by a more of The emergence of political the and forms of governance, as as the and power of In the of a gradual of the ICs transcend their function as a mere dispute settlement to become more than in other we these of the view of sovereignty in the of the international of human domestic a in the scope of rights to their systems, legislative in this area are often to and the one the to and the to which they are is the for be in but the be to individuals who to to the for this least of as a fundamental of the other the capacity of to their the international has For to a in the of a but to against the and domestic courts their to the Court of This might the in order to the of fundamental rights in the of such as the to as against of in their ICs interpret an of international in an a mere function of dispute and public in a that is to a representation a significant of discretion in the and international law in order to They in and they rights in a international the international and the domestic the of The of this are international human rights courts in rights bodies on on tribunals impose on to with of legitimacy have in the of these To the that ICs are the of international they to the that domestic courts for legitimacy to the of and typically between such a conception and a the factors that the of actors the and of & be as they are the of a process of and with political this on of these of legitimacy are For the for about the legitimacy of ICs their as of in the of and the other an legitimacy is this and and in and domestic For the legitimacy of the states and and and individuals have to this as against their This a significant for the and and has to their from in a is more the international than as ICs to in a in order to actors to with their states their and of public as domestic might be the system as with other international ICs they are as by democratic & p. insofar as the international judiciary it becomes more from a democratic that who are by such system that they are their own p. In the the democratic legitimacy of ICs is based on to to their Moreover, international adjudication is of as to to on this are to the in which to judicial is and to of procedural the the it in a and the in & such an democratic for the of public by the international judiciary is in with the new of ICs as bodies with significant In the for the legitimacy of domestic be to the international as the a and which a democratic for claim to These about legitimacy have become more in the current of populist that to democratic to and international The against human rights and global of this also entails a against international courts and quasi-judicial For in and a number of public have to from the and to the of sovereignty to a The the on and other the of against and has also been as to the of political as a against the sovereignty of a democratic In order to these legitimacy have to ICs in democratic the International scholars the that national and transnational as the should as a for of ICs (Bogdandy & Venzke, 2014; Grossman, 2013). This the democratic which tend to become and the institutional of ICs, and their need for processes of political The of jurisdiction by ICs is in the of a more of public of legitimacy to be in this toward is an increasing focus on of accountability and on the need to the independence of ICs and other bodies with a their power and it with the of The of a is typically to the of the in of international law and to for in a conception of In for has to the of the the of domestic institutions that be the of the of seek to by international to domestic and the legitimacy of ICs & 2014; to are in a number of For in the mandate of the entails that and to and should be by the as a a is to and In the human rights the has on the of more in the of the from states & in the of the Court of have with in to that domestic are to human rights and the rule of law p. for have been with to & In from this the legitimacy of ICs insofar as they are perceived as with and domestic of democratic is perceived as a they rather than domestic a the autonomy of the international system is in of an model of public that claim to legitimacy in this is in their but ICs with states in a global rule of law. that this conception on the relation of ICs with domestic and on the of et al., et al., 2014; Hayashi & Bailliet, Yet these and other to institutional mechanisms to ICs to domestic processes overlooking a deeper legitimacy to the of and of have attention in the of international they are crucial courts are to as of marginalized of judicial and a for the of by courts The conception of public accountability is based on the of but the of minorities and identity and domestic The that to adjudication legitimacy judicial processes are as a to protect the rights of is a that such and to divides and of the In the current of growing populist democratic and against rights, this is For one by democracy against the values in human rights that are in as constraints on This conception of rights as on sovereignty is in the of a of “the leaders typically a politics of to and against that are as to and In this conception of democracy as the against rights often place often by an of public including are into executive are is by on of and is and and on The of a model of in diverse states a of this about to to the need of new of and rights as rights a number of some of in order to and other rights of and national Yet and the of the between the and in a of and to global have as a to such and human rights of and to other 2014; & In of such as the current global to that on international human rights The claim is that are between human rights and such as the of from In the of this the to a view of the based values to that are perceived as of of political to impose to the of human rights, the of minorities in the of national minorities their and rights by an political climate, courts and to protect and forms of transnational with political against states that to protect human for the international judicial by to protect their from International human rights law is in by the and other ICs domestic are for to and of rights and that to the are out in these international judicial International has become an for to The for has a of the of for the and identity of these as of their to This is for that seek for human rights by but to public legislative and of of and rights are often of global human rights that against of the human rights of in minorities et al., to with minorities also in other the with to the crimes in in and of are for in on a international are an in with of particular to Yet, in this to domestic public that remain an between rights the and the identity of the which are as these to the is the of international adjudication in delimiting the between and forms of to remain in the model which in the of the international and in the public accountability of the international is a need of the legitimacy of international adjudication in a that of and ICs are as institutions of global governance, of legitimacy should a the the need for a more the model of democracy to the of domestic and to for the power of ICs as a of to the foundations of the international rule of law. This the need to for democratic legitimacy in international it from the of a the of democratic processes and a more In it that one for democratic legitimacy is to address of with to 2000). on this is a on rule the guarantee of rights, but to and to that are marginalized a of a politics of this the of a conception of democracy as it of the that as to legitimacy international it our view to how different are and in the international than domestic constituencies, a more conception of representation should the of the global as by individuals in diverse and and by growing and To this ICs should seek the but a range of actors who an global in that transcend territorial and This international transnational and global movements, of which have an increasing in global and of global such as human rights, rights and the of the power by ICs might as from a democratic that that are of of domestic Yet international courts should legitimacy their in a for the and of international that is of the of that have to domestic also In with the this conception of legitimacy on forms of toward a of and in the current of against democracy and human rights, this focus the of and that have been by national and other The legitimacy of international from such as but from in the of and a more conception of a global rule of law. of but the is how ICs and how ICs and the individuals and that a diverse global a of this the scope of public accountability of the should be ICs should be to states as but to an international by a of actors that a global the ICs legitimacy democratic and to domestic but rather from their their legitimacy their and a diverse global states and national to access international mechanisms of and ICs a that to law from the an to the of and other and to treat their they a potential the To the that they and public to that are in democratic they of and In doing so, is international law in that this but international adjudication has the potential of a for and the and to in 2014; & The of legitimacy to international the potential of in a of international law ICs in on to and on global public on by a of in the international This to the need of making global including ICs, more and 2012). focus on independence and in the to ICs to domestic for this as is no of the law that the of This is to that to independence and are to the also PĂ©rez, Yet the of a and the of the are to on the to a representation of the of minorities in public institutions to the in states with a diverse the 2000). The so-called of to the of identity is seen as in the of democratic legitimacy and has in domestic that for judicial The is the international and how to the legitimacy of the dimension of in the international might be to a of shared of the international The representation of states has been an for ICs, but other forms of have been in international the about the of in ICs which has attention in and the for a more about legitimacy and in the international and other international scholars have such be to the of for such (Grossman, also Hennette-Vauchez, 2015). is the but of the problem might be that judicial and are to on this of of international are often to political to political which on the of to be as international as international The of a of the legitimacy of ICs, their public is that representation is to as with genuine rights to the public to international human rights which in order to this the of has as an of rather than of pp. typically that no from their from in public a that it of a become as the of as as This entails that democratic legitimacy be in that are to forms of as as of in public institutions is of are from the of also the international The of for other than that be the of to it of processes that one another to in it the constraints some in their and as the of the of their as with who in their have more pp. The of to a of and political and systems, the of and in which individuals in a This as to the of but they from to rules and in pp. In they systems, including of tend to be in and that individuals this of to of often are which as of harmful as pp. are to be the of the To the that democracy that a have the that they are this rules out the of from representation the of of to the and the rules that will This the democratic legitimacy of the of and political including public adjudication a of and of democratic a of and a of legitimacy that This of the of and approaches, which have that the of international law a et al., 2000). might also processes how they to the and of potential in the of public as a for democratic the for increasing in ICs be from other more as I focus on such one to public the other to the of is as the representation of the in international but also of a of and which are to the of international adjudication as a public of is for from a and that also the of in of in identity which are typically from the public and to a in this is in the which has a as an to and of it to a more of as in the of institutions to their to more is an of shared identity and values as of a which an of institutional in the that the domestic that in tend to as as and other they that they will a and and have typically been against a of These might be to which are the of with in with the of that are of such as the in the system of in the with a of of that a identity domestic and which have a are for the international we legitimacy from the of which have a in international more in international The of from the by in the the of on institutional legitimacy (Alter, & of representation which tend to to to of judicial but to that the is a of who are against their a international is as power rather than processes and as to the and of and is that a in the to the appointment of an from The in of of their rights, which on the of minorities to access and mechanisms the are in a global by power and about and actors of are to in international which for the of their in international these in a toward the of from Yet international mechanisms are to often of in they are often as and is for an international system that to to of of which might on the of international to institutional becomes to the and of the and in ICs a more with a diverse global public might be crucial to the of ICs 2015). To be on will For the populist that are the of international adjudication it have the and in & 2017), they might more diverse courts as Yet also for populist be a in courts they often as the other ICs might from a to diverse in order to in the of to the In by and other forms of ICs their legitimacy the of of transnational and a to institutions be perceived as in the of and 2012). than in other individuals as of and In this be that and of procedural also has an as institutions have a human the representation of the and identities that remain marginalized in building international institutions might be crucial to the of and democratic legitimacy. International as should function as a of judicial the and of minorities and marginalized states as genuine of the international an to the of of national others, and to treat their they have a and democratic might to a of and which it to of a genuine of To the that some litigants, the judicial processes as against their their and it is to as a for the perceived legitimacy of In the for more also be to the of some the process and of are by of et al., 2013; 2013). This of has significant adjudication is typically as a and and the of and institutional domestic and are as and should this of rather than their of Yet this view of as and who as a from about judicial and from of in the that as as of a by of and Grossman, 2012). such identities political need to the and of are of their a more approaches, with as a with the that is a by we the and a is a that the of the a in and in judicial The potential from of the but also from et al., which the of in in this to the capacity and to be and and which be by the as a of a For be ICs and political rights and rights, as this has and to and a interpret that in the of Yet, are by an such an the of rights such as an of rights that a political For this and that their are by in to and are to with their the of that an In the of a crucial for judicial in this should be in a might with but a more is an but has an This dimension be the is of the of in is to the specific from the of For might a of as toward the by they might to the interpret in that a their which in to of this problem be in of and the to a In a of the Court has a in of on the to in of the In these the Court the of the and of the as a of as a of but the of the to the is as who that they to the the against the to the in public is based an as is no that the other to others, that the have been of in these the Court as the of the which based on an of others, the of of and of in The is of and and this is a of to of cultures. The Court to the that and of in the might have also been by and a of of as they are to be are as the The of such of potential be into the of other international The of is a as but also in the territorial that have international including the International Court of in have out that the to in of of to more these of might be seen as of the to by to the of international law are and a process that is but also and a more diverse international mere the of identities and their increasing the number of and also of who to the of by and that are typically in who to a and and who to the of in In the of the a judicial of to more making of potential to the imposition of more to in The is by that the of a is on a of principles but on the capacity to the of a 2013). from a of and will diverse to on to judicial and the of The of this is by the of in one of the the the in the a to the of the and against the of the by the in of and an on the of the national the to a as the to the of the rights and of and the of public the of the to the of the as an that it have a it be it should be that the in that the of The also the of in of rights and that to for with In own is in is the of who the and who To international adjudication is confronted with a legitimacy that be by forms of democratic the of ICs to the and by transnational minorities and states that remain the of international and as identities and a in the growing of global institutions as to and be the international and by the are on but on who has the power to create and interpret international which are for global of human rights, for are seen by as for the global of of and scholars have called for an of human rights and law with and 2014; and we need a more of human more of The be of other areas of international from law to territorial To this end, we need to ICs, as other institutions of global governance, into more and as a of a and more conception of legitimacy. the of legitimacy a To be the of a global constituency significant to the of the democratic of institutions of global governance, including Yet, as I have ICs should domestic in order to but rather should a for and of who seek to states for and human rights This model of legitimacy an of the international by states but by and The of to the about the of which have been typically from a that on the representation of states and their in appointment the under which ICs are to as of minorities and marginalized become we of the To be some attention has been in to the of in international bodies, to a growing of the in this (Grossman, & 2017; Yet the on institutional and has a more of such as the and in which international are a the of has been in The of the has for to in and the of the process and of These are as rather than of it is the mere of and of and the dimension of more diverse also crucial to the of judicial more forms of as the legitimacy of judicial This a shift from the of international judicial toward the democratic and of a more international The has the potential of the of ICs in to from the political the of and ICs might be more in as democratic institutions and their be as In a more of should also into the by minorities and the legitimacy of international adjudication might to the system and it from democratic by populist movements that the international I to and for their and as as their the process that to this in the by the global I also to the of the of which the of the of the a by and in I to in this for their and also to in the international law the a on a and to for to for and of and to for by et is the on and a the International of the is also an of has the of and areas are international human rights rights and of and is a on and of International by the is the of as

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