ABSTRACT
In international commercial arbitration, pre-award protective measures are essential to ensure the effectiveness of arbitral awards.2 Such measures may be necessary to preserve the subject matter of the arbitration, to maintain the status quo during the arbitral proceedings, or to secure the eventual payment of an award.3 Van den Berg explains that if no pre-award protective measures are available, ‘an award in favour of a creditor may turn out to be a Pyrrhic victory. At that time the debtor may well have “sheltered” his assets in another jurisdiction’.4 Indeed, requests for such protective measures are becoming increasingly common.5
