International Commercial Arbitration in Russia and England

This study is devoted to a comparative legal analysis of international commercial arbitration procedures in ICAC, the most prominent Russian arbitration institution, and LCIA, one of the largest arbitration centres and a strong rival of the ICAC in terms of disputes involving the parties from the CIS countries and other economic regions of the world. A detailed comparative analysis of ICAC and LCIA the historical development, administrative structure, and issues arising on the stages of commence of the proceedings, formation of the tribunal, conduct of the proceedings and making a decision was conducted. As a result, it is suggested for ICAC to increase the national diversity of the administrative bodies and expand the lists of arbitrators with foreign experts, overcome disproportion in the arbitration fee, improve the procedure of written communication between parties, develop a time limit for forming the arbitration tribunal, introduce the duty of the arbitration tribunal to propose for the conduct of each particular arbitration. LCIA procedures proved to be more efficient than ICAC procedure, however, a number of suggestions were developed in order to improve the LCIA Rules, in particular, the introduction of a mixed system for calculating the arbitrators' fees, giving the LCIA Arbitration Court the authority to preliminarily assess the existence of an arbitration agreement and existence of possibility to conduct the proceedings in LCIA, introduce the necessity of draft arbitration scrutiny by the Secretariat.