ratification, the Convention will enter into force. Once Mexico ratifies the Convention, it will be the 154th country to do so. Mexico’s decision to sign the ICSID Convention has been viewed generally as confirming its commitment to welcome foreign investments. It will certainly foster an atmosphere of confidence among current and future Mexican investors and is likely to stimulate a larger flow of investments into the country, particularly as Mexico is one of the signatories to the Comprehensive and Progressive Trans-Pacific Agreement (CPTPP). Mexico is New Zealand’s 21st largest export market SIAC proposal for consolidation of arbitration proceedings between arbitral institutions On 19 December 2017, the Singapore International Arbitration Centre (SIAC) released a proposal on cross-institution cooperation and consolidation of arbitral proceedings conducted under different arbitral rules (Proposal). Currently, the arbitration rules of most arbitral institutions (including those of NZIAC and NZDRC) contain provisions for consolidation of arbitral proceedings into a single arbitration under certain conditions. These consolidation provisions typically require, among other things, that the parties’ arbitration agreements are ‘compatible’. A necessary element of compatibility is that the arbitration agreements refer to the same institutional arbitral rules. The Proposal involves adoption of a protocol permitting the cross-institution consolidation of arbitrations subject to different institutional arbitration rules (eg, SIAC and New Zealand International Arbitration Centre (NZIAC) arbitration rules). The Protocol sets out the framework for the review of consolidation applications when two or more arbitration institutions are involved and which would govern which institution would administer the consolidated proceedings. Under the Proposal, the consolidation protocol would form part of the arbitration rules of the participating institutions. On the face of it the Proposal is a welcome initiative in terms of inter-arbitral institution cooperation and addressing the risk of inconsistent awards arising out of concurrent proceedings in different jurisdictions and time and cost implications for parties involved in multiple proceedings, however there would seem to be some inherently challenging obstacles to its efficacy, and ultimately, to its acceptance and adoption - none the least of which are the key issues of party autonomy and certainty (of jurisdiction, procedural rules, composition of tribunal, time for award, tribunal fees, administrative costs, enforcement etc) that are fundamental tenets of modern commercial arbitration. While the Proposal suggests that a deeming provision be included in the rules of the participating institutions, such form of party ‘consent’ may come as some surprise to parties who find themselves required to arbitrate under a different institution and under quite different rules and on different terms to those they signed up for when they entered into the underlying contract or transaction.