A major concern for any outside investor in the Middle East's largest economy is that arbitration in Saudi Arabia is notoriously complicated, time-consuming, and prone to interference by the local courts, while arbitral awards have often faced difficulties in being enforced.A new Saudi Arbitration Law3 was issued by Royal Decree No. M/34 on April 16th, 20124 (the “New Law”), which came into force on 9 July 2012.5 The New Law, which is covered in 58 Articles, is intended to alleviate many of the shortcomings of the Saudi Arbitration Law of 1983 (the “Old Law”) and strengthen investors' confidence in the effective resolution of potential disputes in Saudi Arabia.As a result of the growth of international commercial interaction, the number of disputes has increased and arbitration is often considered to be the preferable method of dispute resolution for reasons of expediency, technical specialization, or in order to avoid potential bias that might be encountered in national courts. Issues of arbitral award recognition and enforcement can be serious obstacles to swift dispute resolution, however, as varying customs, laws, cultures, and in the case of Saudi Arabia, religions, may result in conflicts in applying foreign arbitral awards. Saudi Arabia is an example of how a lack of a nuanced understanding of those factors can result in adverse results. Without understanding Saudi culture and the laws that regulate foreign arbitration, the country can be dismissed as anti-arbitration. Yet, there is a renewed drive to promote arbitration in Saudi Arabia, as part of the larger overhaul of the legal system in the country, in order to promote economic development. This paper presents a framework for the new updated Saudi arbitration law while laying the ground for a cautionary approach, if factors such as culture, laws, and practice are taken into consideration. The article provides a much-needed examination of the legal provisions of the New Law by way of comparison against the provisions of the Old Law and the United Nations Commission on International Trade Law (UNCITRAL) Model Law. The paper further discusses arbitrability based on efficiency, justice to the parties in the individual case, and societal values
