This paper is purported to offer a comparative approach to the procedural mechanisms by which the enforcement provisions of the ICSID Convention have been implemented under the legal systems of the United States and Germany. The comparative analysis will take into account the procedural...

Under the national procedural rules of most countries, judicial assistance in aid of international arbitration will be granted only by the courts at the seat of the arbitration (absent a letter rogatory from a court of the arbitral seat to a court in another jurisdiction). Germany, following an...