Arbitration in Serbia: A Complete, Business-Focused Guide for Foreign Companies (with London & Dubai Perspectives)

Prepared by Tahmidur Remura Wahid (TRW) Law Firm — Dhaka · London · Dubai

Foreign investors increasingly look to Serbia for manufacturing, energy, infrastructure, technology, and logistics plays across the Western Balkans. With cross-border contracts comes the need for a fast, neutral, and enforceable dispute resolution mechanism. Arbitration, when drafted and executed well, gives foreign companies precisely that. This guide distills what an in-house counsel, CFO, or deal team should know before a dispute arises and during an arbitration seated in Serbia, with practical comparisons to proceedings seated in London and Dubai to help you decide what to choose and how to manage risk across jurisdictions.

Looking for hands-on support with arbitration clauses, emergency measures, or award enforcement? Explore TRW’s International Arbitration practice (internal): TRW — International Arbitration.

Why foreign companies choose arbitration for Serbian deals

Speed, neutrality, and enforceability are the three reasons our international clients prefer arbitration over state courts for Serbian-related contracts.

• ■ Speed & process control: Tailored timetables, agreed rules, focused document production, and case management tools keep matters moving.
• ■ Neutral forum: Particularly helpful where the commercial counterparty or state-linked entity prefers the “home court.”
• ■ Enforceability abroad: Foreign arbitral awards are widely enforceable under the New York Convention in over 160 jurisdictions, which is decisive for cross-border asset strategies.
• ■ Expert decision-makers: Tribunals can be built with sector-specific and technical expertise.
• ■ Confidentiality: Sensitive pricing, know-how, and investment structures usually stay outside the public record.

Snapshot of the Serbian arbitration framework

Serbia’s modern arbitration law is Model-Law inspired and friendly to international commerce. Practically, that means:

• ■ Freedom of contract on procedure: Parties may adopt institutional rules (e.g., rules of a Serbian arbitral institution) or agree on ad hoc arbitration (e.g., UNCITRAL Rules).
• ■ Competence-competence: Tribunals decide their own jurisdiction as a first instance, with limited court interference.
• ■ Court support without court control: Serbian courts can assist with interim measures and evidence, while respecting the autonomy of the arbitral process.
• ■ Set-aside is narrow: Annulment is limited to specific grounds (e.g., invalid agreement, due-process breaches, excess of mandate, non-arbitrability, public policy).
• ■ Recognition & enforcement: Foreign awards require recognition in Serbia, aligned with New York Convention principles; Serbian awards are similarly enforceable abroad.

What this means for you: If you draft your arbitration clause carefully and manage your proceedings professionally, Serbia offers a predictable and efficient route to a final, enforceable result.

Institutions you will actually encounter (and when to go ad hoc)

In Serbia, you are likely to see either:

• ■ Permanent Arbitration at the Chamber of Commerce and Industry of Serbia.
  Good fit for commercial disputes with Serbian counterparties, a local seat, and parties who value a Serbian administrative backbone.
• ■ Belgrade Arbitration Center (BAC).
  A modern option oriented toward international users, with rules aligned to contemporary best practices.

Ad hoc (UNCITRAL Rules) vs. Institutional:
Ad hoc arbitration gives maximum flexibility and can reduce administrative fees, but it demands a sophisticated clause (appointing authority, consolidation/joinder, emergency relief) and experienced counsel to avoid procedural dead-ends. Institutional rules provide tested procedures, a case manager, fee schedules, and ready answers when parties disagree on mechanics.

TRW tip: If your deal team is not deeply experienced with ad hoc arbitration, prefer an institutional clause—especially for multi-party, multi-contract projects in construction, energy, or telecoms.

What is arbitrable (and what is not)

Most contractual and commercial disputes are arbitrable. Areas with limits tend to involve insolvency proceedings, certain corporate matters, real estate in rem rights, or public-policy sensitive issues.
Practical takeaway: Don’t assume arbitrability—stress-test your clause for your specific sector (e.g., public procurement addenda, concession agreements, regulated assets, IP assignments with local registrations). Where parts of a dispute may be non-arbitrable, draft fallbacks (exclusive court jurisdiction for those elements, severability language, and coordination provisions).

How to draft a strong arbitration clause for Serbia-related contracts

Well-drafted clauses win disputes before they begin. Use this checklist when finalizing your Serbian deal documents:

• ■ Institution & Rules: Identify the institution and its rules (or UNCITRAL Rules for ad hoc).
  Example: “Any dispute arising out of or in connection with this contract shall be referred to and finally resolved by arbitration administered by [Institution], under the [Institution’s] Rules in force when the Notice of Arbitration is submitted.”
• ■ Seat of arbitration: Choose Belgrade if you want Serbian lex arbitri and local court support; choose London or Dubai if you need the supervisory court and procedural culture of those cities. The seat is not the venue—you can still hold hearings elsewhere or virtually.
• ■ Governing law of the contract: Pick the law that governs substantive rights (e.g., English law for finance or commodity deals; Serbian law for asset-heavy local projects). Avoid silence, which invites conflict-of-laws squabbles.
• ■ Number & method of appointment of arbitrators: Always specify an odd number; for higher-value matters, three arbitrators are common. Include a naming method or appointing authority fallback.
• ■ Language: English is the default for most cross-border deals. If Serbian documents or witnesses are expected, anticipate translation logistics and cost.
• ■ Consolidation & joinder: If your project has back-to-back subcontracts or consortia, include consolidation and joinder powers, with cross-consents where possible.
• ■ Emergency relief: Consider adopting rules with emergency arbitrator provisions or spell out access to courts for conservatory measures without waiving arbitration.
• ■ Confidentiality: If not guaranteed by the chosen rules or law, add a confidentiality covenant covering pleadings, transcripts, memorials, rulings, settlement communications, and award (subject to enforcement disclosures).
• ■ Multi-tier clauses: Pre-arbitration negotiation or mediation windows (e.g., 30–45 days) can resolve many disputes commercially. Make pre-conditions clear and time-bound to avoid jurisdictional satellite fights.
• ■ Service of process: State specific service addresses and methods (including email) for the Notice of Arbitration to avoid procedural ambush.
• ■ Digital evidence & cybersecurity: Permit e-bundles, define secure data rooms, and set treatment of personal data and trade secrets.

Choosing the seat: Belgrade vs London vs Dubai

Your seat determines the lex arbitri (arbitration law), the supervisory court, and the procedural culture that will fill gaps in party agreement.

Belgrade (Serbia)

• ■ Why choose it: Lower cost base, proximity to Serbian assets and witnesses, supportive courts, Model-Law style predictability, convenient for Balkan projects.
• ■ When it shines: Localized disputes (supply, EPC, O&M), state-linked counterparties where Serbian law governs, and where enforcement is expected primarily in Serbia or nearby states.
• ■ Watch-outs: If you expect aggressive common-law style discovery or complex anti-suit issues, calibrate expectations and tailor procedural rules accordingly.

London (United Kingdom)

• ■ Why choose it: A global arbitration capital with a deep bench of arbitrators, well-honed procedure, pro-arbitration courts, and comfort for international finance, energy, and M&A.
• ■ When it shines: Deals governed by English law, multi-party financial transactions, commodity trading, and disputes where worldwide interim relief strategies (e.g., freezing orders) may be needed.
• ■ Watch-outs: Higher cost profile; plan budgets and fee controls. Keep an eye on any evolving statutory tweaks to the arbitration framework (TRW tracks these for clients).

Dubai (UAE)

• ■ Why choose it: A strategic hub for Middle East–Europe–Asia trade, strong regional enforceability for awards, modern institutional rules, and sophisticated tribunals.
• ■ When it shines: Projects and joint ventures with regional assets, logistics, and financing ties; parties with UAE presence; bilingual proceedings options; award enforcement routes across the GCC/MENA sphere.
• ■ Watch-outs: Select the appropriate institutional rules and seat carefully (e.g., onshore vs. financial-free-zone contexts) to align with your enforcement map and comfort on court supervision.

Bottom line: Choose Belgrade if your matter is Serbia-centric in substance and enforcement; choose London where English law, complex finance, or worldwide asset protection dominate; choose Dubai where regional assets or counterparties live and where you need MENA-centric enforceability.

How proceedings unfold in practice (timeline & milestones)

While each case management conference will tailor a schedule, a typical international arbitration lifecycle looks like:

1. Notice of Arbitration & Answer

• Starts the case; identifies claims, relief, and contract(s).

1. Constitution of the Tribunal

• Sole arbitrator or three; confirm independence; discuss availability and timetable.

1. Procedural Conference (PO1)

• Fixes calendar, scope of disclosure/doc production, protective orders, format of witness/expert evidence, and hearing logistics.

1. Written Pleadings

• Claimant memorial with fact exhibits, witness statements, and expert reports; respondent counter-memorial with its evidence; subsequent replies as needed.

1. Document Production

• Narrowly tailored requests (e.g., Redfern Schedules), tribunal rulings on scope and proportionality, rolling productions.

1. Fact & Expert Evidence

• Witness conferencing (“hot-tubbing”) for experts in construction delay/quantum or pricing can be highly efficient.

1. Hearing

• Hybrid or virtual hearings are common; allocate time strictly (chess clocks) to keep costs under control.

1. Post-Hearing Briefs (if needed)

• Focused submissions on agreed legal issues or numbers (e.g., interest, currency, costs).

1. Award

• Final, partial, or interim; typically with cost allocation and interest. Consent awards available upon settlement.

TRW tip: Front-load your factual record. The cheapest documents to collect are those you secure before positions harden. Align corporate IT, preserve key custodians, and lock a clear narrative early.

Interim and conservatory measures (in Serbia and abroad)

Foreign companies often need urgent protection: stop asset dissipation, preserve evidence, secure performance, or maintain the status quo.

• ■ Tribunal-ordered measures: Once constituted, tribunals can order interim steps (status quo, anti-dissipation, escrow, security for costs).
• ■ Court-ordered measures in Serbia: Before constitution or in parallel, Serbian courts can grant interim measures without waiving arbitration—useful for quick relief on local assets.
• ■ Cross-border strategy: If your enforcement map includes the UK or UAE, consider supportive court relief in those seats too (e.g., freezing orders in England; urgent measures in Dubai), coordinated with your Serbian seat and tribunal timetable.

Practical play: Draft your clause to allow recourse to courts for interim relief “in aid of arbitration,” explicitly stating such applications do not breach the arbitration agreement.

Evidence, privilege, and confidentiality

• ■ Disclosure scope: Expect targeted document production—arbitration is not U.S.-style discovery. Frame requests precisely and proportionately.
• ■ Privilege: Align on applicable privilege regimes early (in-house counsel in civil vs. common-law settings, communications with third-party consultants, settlement privilege).
• ■ Confidentiality orders: Where rules or law do not provide automatic confidentiality, tribunals routinely issue protective orders for trade secrets and personal data.
• ■ Data handling: Define secure e-bundling, access rights, and retention/destruction schedules.

Costs, budgeting, and how to keep spend under control

Arbitration costs include arbitrator fees, institutional fees (if any), counsel fees, experts, transcription/translation, and hearing venue/technology. Serbia’s cost base is lower than London or other Western European hubs. Control levers:

• ■ Pick the right tribunal size: Sole arbitrator for mid-value matters can save materially.
• ■ Strict procedural calendar: Limit rounds of submissions and page counts; use chess clocks.
• ■ Targeted document production: Avoid broad fishing expeditions.
• ■ Expert scope management: Combine delay and quantum expertise in construction, use joint expert statements, or expert conferencing.
• ■ Early settlement windows: Bake in WP (“without prejudice”) checkpoints post-document production when reality-testing is strongest.
• ■ Costs-shifting: Tribunals often apply “costs follow the event” with reasonableness checks; keep time records and phase budgets to support recovery.

Third-party funding and security for costs

International funders are increasingly open to Central & Eastern Europe claims with recoverability and merits. If you are respondent facing a funded claimant, seek security for costs where appropriate. Claimants should prepare early funding packets (merits memo, quantum model, enforcement map, budget).

Recognition, setting aside, and enforcement: mapping the endgame

• ■ Setting aside (annulment) in the seat: Grounds are narrow (jurisdiction, due process, mandate excess, non-arbitrability, public policy). An annulment application is not an appeal on the merits.
• ■ Enforcement abroad: Use the New York Convention pathways; expect challenges on standard grounds (invalid agreement, notice issues, ultra petita, due process, public policy).
• ■ Enforcement in Serbia: Foreign awards require recognition; Serbian courts align with Convention tests.
• ■ Asset strategy: Before you file, map the counterparty’s assets (Serbia + abroad), identify bankable jurisdictions, and run parallel recognition applications where lawful to increase pressure.

TRW tip: Consider currency of the award, interest mechanics (simple vs. compound, pre- and post-award), and tax consequences at the drafting stage to avoid avoidable haircut at the cash-collection phase.

Sector-specific notes for foreign investors

Energy & renewables

• Issues: change-in-law, offtake pricing, grid connection delays, curtailment, stabilization clauses, environmental permitting.
• Playbook: Stabilization baskets tied to regulatory changes; detailed force-majeure; metering & loss factors; step-in rights; expert-first pathways for narrow technical disputes before full tribunal.

Construction & EPC

• Issues: delays, unforeseen site conditions, design development risk, supply chain shocks, payment milestones, performance security.
• Playbook: Harmonize FIDIC with Serbian law quirks; agree delay analysis method; caps/LDs; DAB/DAAB step; joinder/consolidation across contractor-subcontractor-owner.

Telecoms & tech

• Issues: SLAs, latency/uptime, data localization, IP ownership, exit and transition services.
• Playbook: Evidence-friendly logging, API audit trails, cybersecurity obligations; confidential carve-outs for regulatory disclosures.

Banking & trade finance

• Issues: sanctions, KYC/AML breaches, force-majeure in commodity flows, interest and gross-up clauses.
• Playbook: Hardwire English law for finance docs but keep Serbia seat or London seat based on enforcement map; add carve-outs for interim relief in Serbia/England/UAE courts.

Ten mistakes foreign companies make (and how to avoid them)

1. Using a vague dispute clause (“courts or arbitration somewhere in Europe”).
   Fix: Use a precise institutional clause with seat, rules, language, and appointment mechanics.
2. Ignoring arbitrability trip-wires (e.g., corporate registry or insolvency-adjacent issues).
   Fix: Stress-test arbitrability at term sheet stage; use carve-outs.
3. Leaving governing law blank or inconsistent across the deal suite.
   Fix: Harmonize or deliberately mix with signposted conflict-rules and consolidation tools.
4. Under-specifying joinder/consolidation in multi-contract projects.
   Fix: Add cross-consent language and tribunal powers to avoid parallel proceedings.
5. Assuming full U.S.-style discovery.
   Fix: Build targeted doc-production with objective custodians and keywords; rely on expert conferencing.
6. Forgetting pre-arbitration steps (negotiation/mediation) that are drafted as conditions precedent.
   Fix: Calendar these steps; document good-faith efforts to avoid jurisdictional ambush.
7. No plan for interim relief before tribunal constitution.
   Fix: Clause permitting urgent court measures “in aid of arbitration”; emergency arbitrator options.
8. Weak translation/data protocols.
   Fix: Early translator engagement; bilingual indexes; protected data rooms.
9. Budget creep from uncontrolled memorials and experts.
   Fix: Phase budgets, page limits, chess clocks, joint expert statements.
10. Waiting on enforcement strategy until after the award.
    Fix: Build an asset map and enforcement game plan before you file.

Managing a Serbia-seated arbitration from London or Dubai

Many foreign clients run Serbia-related arbitrations from their European or Middle Eastern HQs. Here’s how to make that work smoothly.

• ■ Seat vs. management location: Even if Belgrade is the seat, you can coordinate counsel and experts from London or Dubai, hold virtual CMCs, and schedule hybrid hearings.
• ■ Interim relief complementarity: If the counterparty or assets touch the UK or UAE, budget and prepare for supportive court measures there, synchronized with Serbian steps.
• ■ Arbitrator selection: Build lists that blend local legal familiarity (for Serbia-law issues) with international procedure expertise (case management efficiency, complex damages).
• ■ Time zones & language: English-language proceedings are standard for cross-border matters; plan for Serbian translations of key corporate records, board minutes, or permits.
• ■ On-the-ground support: TRW teams in Dhaka, London, and Dubai coordinate filings, evidence, and hearing logistics with trusted Serbian co-counsel and institutions.

Settlement dynamics and consent awards

Commercial resolution remains underused leverage. Use the following cadences:

• ■ Post-pleadings: Once both sides have committed their narrative, the delta is clearest.
• ■ After document production: Reality bites when contemporaneous emails and logs land.
• ■ After expert joint statements: Differences narrow; numbers turn from advocacy to arithmetic.
• ■ Consent award: If you settle, request a consent award so that the settlement is enforceable like any award (subject to public-policy limits). This can be critical when obligations are staged over time.

Governance, compliance, and signing mechanics (don’t lose on a technicality)

• ■ Capacity & authority: Ensure signatories have corporate authority; attach board resolutions; where needed, notarization and apostille/legalization.
• ■ Power of attorney: Tribunals will scrutinize POAs; make them specific, dated, and translated if required.
• ■ Sanctions & AML/KYC: Embed warranties and termination rights; manage banking channels for award payments to avoid blocks.
• ■ Data protection: If EU personal data will surface, set GDPR-compliant transfer and processing terms.
• ■ Language hierarchy: State which version prevails if bilingual contracts are used.
• ■ Notices: Define email and courier methods; track delivery proof meticulously.

Case management playbook for in-house teams

• ■ Establish a dispute file early: Chronology, cast of characters, issues list, document map, damages model.
• ■ Custodian interviews: Short, recorded (internal) witness notes preserve recollection; lock down key devices.
• ■ Damages model first: Anchor your relief and valuation; it shapes discovery and expert scope.
• ■ Trial bundle discipline: Use e-bundles with stable pagination; shared indexes reduce hearing time.
• ■ Board communications: Provide a one-page dashboard (budget to date, key dates, settlement range, enforcement plan).
• ■ Privilege guardrails: Train teams on what to write (and not) in email; use counsel-client headers for legal advice.

When should a foreign company not seat in Serbia?

• ■ Finance-heavy disputes governed by English law where parties expect English court support and worldwide injunctive tools.
• ■ Multi-party global disputes where London seat offers predictable consolidation orders and specialist benches.
• ■ When UAE or GCC assets dominate, and the parties prefer Dubai seat for regional enforceability and institutional familiarity.
• ■ Where you need maximum neutrality optics and neither party has ties to Serbia (London or another neutral seat may be preferable).

That said, for Serbia-centric projects and enforcement targets, Belgrade is often optimal on cost, convenience, and local court support.

How TRW runs Serbia-related arbitrations across three hubs

Integrated cross-border model:
TRW assembles matter teams spanning Dhaka–London–Dubai, giving clients round-the-clock coverage, cost-efficient drafting engines, and on-the-ground coordination with Serbian institutions and local counsel.

• ■ Front-end: Clause drafting, risk registers, procurement playbooks, and training for deal teams.
• ■ Mid-stream: Case strategy, tribunal selection, expert curation (delay/quantum/valuation), and interim-relief coordination in multiple courts.
• ■ Back-end: Award enforcement mapping, debt recovery toolkits, and settlement structures (escrow, parent guarantees, staged payments).
• ■ Fee alignment: Phased budgets, caps for written rounds, and success-linked components where appropriate.

Quick reference: model clause (customize!)

Model Arbitration Clause (illustrative only; tailor to your deal)

“Any dispute, controversy, or claim arising out of or in connection with this Contract, including any question regarding its existence, validity, or termination, shall be referred to and finally resolved by arbitration administered by [Institution] under the [Institution] Rules in force at the time the Notice of Arbitration is submitted.
Seat: Belgrade, Republic of Serbia.
Tribunal: Three arbitrators; each party shall nominate one arbitrator; the two party-nominated arbitrators shall jointly nominate the presiding arbitrator; failing which, the [Institution/Appointing Authority] shall appoint.
Language: English.
Governing Law: [e.g., English law/Serbian law/other].
Joinder & Consolidation: The Tribunal shall have the power to join third parties and consolidate related arbitrations arising out of substantially the same facts or transactions.
Interim Relief: Applications to any competent court for interim or conservatory measures shall not be deemed incompatible with this agreement to arbitrate or a waiver of the right to arbitrate.
Confidentiality: The parties shall keep confidential the existence of the arbitration, all pleadings, evidence, transcripts, orders, and the award, save as required by law or for enforcement.”

Variations: Swap the seat to London or Dubai if that better fits your enforcement map and corporate governance preferences. For ad hoc, replace the first line with UNCITRAL Arbitration Rules and designate an appointing authority.

A Serbia–London–Dubai decision matrix (executive view)

• ■ Primary assets in Serbia; local counterparties; Serbian law governs → Seat Belgrade; Serbian institution; English language; keep London/UAE courts available for supportive measures if assets also sit there.
• ■ English-law finance or cross-border M&A; multi-party, high-stakes → Seat London; LCIA or other leading rules; expect higher cost but strong procedure and global perception.
• ■ Regional JV with GCC nodes; logistics or energy with UAE nexus → Seat Dubai; modern institutional rules; consider bilingual proceedings and UAE court support.

Frequently asked practical questions (for foreign companies)

Q1. Can we run the arbitration in English if the seat is Belgrade?
Yes. Language is by party agreement (or tribunal order). English is common for cross-border matters; arrange certified translations where needed.

Q2. Can we seek interim relief in Serbian courts without waiving arbitration?
Yes. Draft your clause to say so expressly, and coordinate with tribunal powers when constituted.

Q3. How long will it take?
Case-specific, but with disciplined procedures and a focused tribunal, 12–20 months to a final award is a workable target in many commercial matters. Complex construction or quantum issues can extend timelines.

Q4. Will we recover our costs if we win?
Tribunals frequently award costs on a “costs follow the event” basis, subject to reasonableness. Good budgeting and timekeeping support better recoveries.

Q5. Can we involve subsidiaries and subcontractors in a single proceeding?
Yes—if your clause empowers joinder and consolidation and your contracting suite is harmonized. Otherwise, parallel cases may be unavoidable.

Q6. Are consent awards enforceable?
Yes, subject to public-policy limits. They are a powerful tool to give a settlement the teeth of an award.

Q7. What about third-party funding?
Available in the market. Expect disclosure debates and potential security for costs motions—prepare accordingly.

Action checklist before you sign your next Serbia-touching contract

• ■ Seat, rules, language, tribunal size, appointing authority finalized in the term sheet
• ■ Governing law aligned across main contract and key subcontracts
• ■ Interim relief carve-out and emergency arbitrator option in place
• ■ Joinder/consolidation and multi-contract architecture planned
• ■ Service of notices (including email) crystal-clear
• ■ Confidentiality covenant covering pleadings and award
• ■ Digital handling: e-bundles, secure data room, retention policy
• ■ Arbitrability checked for your sector/regulatory touchpoints
• ■ Asset map of counterparty for a realistic enforcement plan
• ■ Budget/fee model agreed (caps per phase; experts scoped)
• ■ Translations anticipated for key records and powers of attorney

How TRW can help (Serbia × London × Dubai)

• ■ Clause design and deal-stage risk mapping for Serbia-related investments, EPCs, offtakes, and JV frameworks.
• ■ Arbitration management from the first notice to final award: pleadings, evidence, hearing strategy, expert coordination, and cost control.
• ■ Interim relief planning across Serbian, English, and UAE courts without jeopardizing the arbitration agreement.
• ■ Enforcement campaigns where it matters—bank accounts, receivables, trading hubs, and real assets—using New York Convention pathways.
• ■ Settlement architecture: escrow, parent guarantees, performance-linked payment schedules, and consent awards for enforceability.

To speak with our arbitration team today, call the numbers below or email us.

Summary Table — Arbitration in Serbia for Foreign Companies

Topic	Key Takeaways	TRW Practical Tip
Why arbitration	Neutral, faster, enforceable awards; expert tribunals; confidentiality	Choose rules that fit your dispute profile and budget
Institutions	Permanent Arbitration (Chamber of Commerce), BAC; ad hoc possible	Prefer institutional rules unless your team is ad-hoc fluent
Seat selection	Belgrade for Serbia-centric disputes; London for English-law/finance; Dubai for GCC nexus	Map assets and enforcement before fixing the seat
Arbitrability	Most commercial claims arbitrable; watch insolvency/real-rights/public policy	Stress-test sector arbitrability early
Clause essentials	Seat, rules, language, tribunal, joinder, interim relief, confidentiality	Add service mechanics (incl. email) and appointing authority
Interim measures	Tribunal and Serbian courts can grant; parallel support in UK/UAE courts	Say court aid is compatible with arbitration
Evidence & privilege	Targeted production; align privilege regimes; protective orders	Use e-bundles and joint expert statements
Timing & cost	Many cases: ~12–20 months; Serbia cheaper than London	Cap pages, rounds, and expert scopes; chess clocks
Third-party funding	Increasingly available; think security for costs	Prepare a merits memo and enforcement map early
Set-aside & enforcement	Narrow annulment grounds; recognition in Serbia mirrors NYC tests	Draft for interest, currency, and tax; run parallel recognition where useful
Settlement	Best windows: post-docs and post-expert statements; consent awards	Bake in WP checkpoints; keep board-ready ranges updated
Do/Don’t	Do harmonize governing law; don’t leave consolidation to chance	Create a dispute file before positions harden

Contact TRW Law Firm — International Arbitration

Phone (BD): +8801708000660 · +8801847220062 · +8801708080817
Email: [email protected] · [email protected] · [email protected]

Global Offices:

• Dhaka: House 410, Road 29, Mohakhali DOHS
• Dubai: Rolex Building, L-12 Sheikh Zayed Road
• London: 330 High Holborn, London WC1V 7QH, United Kingdom

This article is intended as general guidance. For tailored advice on drafting arbitration clauses, managing ongoing proceedings, or executing enforcement strategies in Serbia (and beyond), contact TRW’s International Arbitration team.