Convention] lack the legal certainty afforded by the Convention, and businesses cannot be confident that commercial obligations can be enforced. This increases the level of risk, meaning that additional security may be required, that negotiations are likely to be more complex and protracted, and that transaction costs will rise. Such risks can adversely affect international trade. For commercial entities, an enforceable award or settlement agreement is much preferred to a judgment of the domestic courts. This is for one simple reason: it is significantly easier to enforce an arbitral award under the New York Convention than to enforce a foreign judgment. The adoption of the Judgments Convention19 this year makes some progress although with only one state having signed the instrument to date, it is yet to be seen whether this Convention will have any impact in practice. In light of the recognised benefits to be attained in adopting arbitration as the process of choice for the resolution of international commercial disputes, work is currently underway within the Trans-Pacific to encourage wider adoption of the UNCITRAL Model Law and accession to the New York Convention with the specific stated purpose of addressing the barrier militating against trade and investment by external parties into the region. In particular, on 12-13 February 2018, the inaugural South Pacific International Arbitration Conference (organised by the ADB, the Government of Fiji, and the UNCITRAL Regional Centre for Asia and the Pacific) took place in Nadi, Fiji. The purpose of that conference was to bring together government officials, legal practitioners, members of the judiciary, private sector representatives, and other stakeholders from nations across the Pacific to discuss solutions to existing barriers to FDI and cross-border trade, including the reduction of risk through the adoption of arbitration as a dispute resolution mechanism for cross-border commercial disputes. During the course of that conference, it was explicitly acknowledged that:20 Data and experience from around the world clearly shows that companies engaged in cross-border trade and investment assign a high degree of risk to developing countries with weak or uncertain dispute resolution systems, and that efficient and effective arbitration frameworks increase confidence and encourage cross-border investment and trade. More recently, on 25-26 March 2019, the 2nd South Pacific International Arbitration Conference took place in Port Moresby, Papua New Guinea. The same messages were imparted again – to encourage trade, you need to minimise the risks and international arbitration under the New York Convention is to be encouraged.21 The overwhelming message from potential investors appears clear. To encourage FDI, those investors must be satisfied that their commercial risks can be adequately managed. From their perspective, the availability of arbitration under the New York Convention will go a long way to meeting this need. B. What impact could the Singapore Convention have? In light of how well the New York Convention is able to meet the needs of potential investors to manage their risks, what role then might mediation and the Singapore Convention play in the Trans-Pacific Region? The results of a short survey undertaken by the International Mediation Institute in October and November 2014 reported that 92.9% of respondents said they would be either “probably” or “much more likely” “to mediate a dispute with a party from another country if [they] knew that country ratified a UN Convention on the Enforcement of Mediated Settlements and that consequently any settlement could easily be enforced there”; 87.8% of the respondents said that “the existence of a widely-ratified Enforcement Convention” would “possibly” or “definitely” “make it easier for commercial parties to come to mediation in the first place”; and 90.5% of respondents said that “the absence of any kind of international enforcement mechanism for mediated settlements” presents a “major impediment” or is “one deterring factor” in “the growth of mediation as a mechanism for resolving cross-border disputes”.22 This would certainly intimate that mediation might be well received by potential parties to an