Enka Insaat VE Sanayi AS v OOO Insurance Company Chubb

Where parties to a contract containing an arbitration agreement have not expressly or impliedly chosen the law governing that arbitration agreement, the chosen governing law of the main contract will generally also govern the arbitration agreement; absent any such choice, the arbitration agreement is governed by the law with which it is most closely connected, which will normally be the law of the seat of arbitration.