Although commercial risk is a natural part of doing business, particularly within the international arena, commercial parties will always seek to minimise and mitigate their business risks as much as possible. An essential element of this risk mitigation exercise is to ensure that there are credible and effective dispute resolution processes in place to determine the parties’ respective rights and obligations should a dispute arise out of the commercial arrangement that is proposed.13 Trans-Pacific states are often characterised as having particular problems when it comes to satisfying international investors and commercial counterparties that any rights and obligations will be enforced and disputes resolved effectively and in accordance with the rule of law. To put it bluntly, foreign investors do not have confidence in the local courts to perform this function.14 Moreover, even where a litigating party obtains a judgment in its favour, it may then need to take steps to enforce the judgment in another jurisdiction which is often problematic. This is where both the New York Convention and Singapore Convention come into their own. B. How can the New York Convention aid foreign direct investment? With respect to international commercial arbitration, and within the context of the New York Convention, four primary benefits have been identified, namely: (a) obtaining a final and binding award which is readily enforceable under the New York Convention; (b) the resolution of commercial disputes by highly skilled and neutral arbitrators; (c) minimising pressure on often over subscribed dockets in local court registries; and (d) providing local lawyers with exposure to international commercial arbitration and the opportunity to engage with legal professionals from more developed legal jurisdictions (thereby aiding the development of those local lawyers).15 The first two of the four benefits identified above are advantageous to the foreign investor (as well as the host country commercial counterparty) and, therefore, are likely to have a positive impact on encouraging FDI. The third and fourth points identify more wide-reaching benefits to the host country rather than a potential foreign investor into that host country (and therefore are not directly pertinent to an evaluation of how acceding to the New York Convention might facilitate greater trade and investment). Nevertheless, they bear passing mention here as they are also important factors in the wider evaluation of whether the New York Convention is a beneficial instrument for Trans- Pacific states to accede to. The first of the points identifies one of the central objectives of the New York Convention, which provides for the simple enforcement of arbitral awards in states which are contracting parties to that Convention. The importance placed on recognition and enforceability (as well as avoidance of specific legal systems or national courts, which to some extent is a corollary of enforceability) can be seen in the results of the 2018 Queen Mary Survey16 which records the three most valuable characteristics of international arbitration to be: enforceability of awards (64%); avoiding specific legal systems/national courts (60%); and flexibility (40%).17 A strong emphasis on the central importance of enforceability was also placed by Kofi Annan in his address at the New York Convention Day on 10 June 1998:18 …entities investing or doing business in [states which are not parties to the New York