Proven results in cross-border disputes. First-chair ICC arbitration win of more than US$614,000 under Hong Kong law. Contributing author, ICLG Investor-State Arbitration 2027. Counsel in ICC, ICSID, LCIA and CAA matters worldwide.

Davy A. Karkason, Founding Attorney

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Transnational Matters PLLC represents investors, multinational businesses, and individuals in international arbitration — treaty and contract disputes with foreign states, cross-border commercial claims, and enforcement of arbitral awards before U.S. courts. Our international arbitration attorneys serve as counsel in ICC, ICSID, LCIA, and UNCITRAL proceedings worldwide: we assess jurisdiction and treaty protection, build the evidentiary record, argue the case, and pursue the award where the assets are. Arbitration itself is a private, binding alternative to court litigation — the parties agree that an independent tribunal will decide their dispute, and the award is enforceable in over 170 jurisdictions under the New York Convention.

What do international arbitration lawyers do? As international arbitration attorneys, we act as counsel and advocate at every phase: drafting and testing arbitration agreements, constituting tribunals, briefing jurisdiction and the merits, examining witnesses and experts, and enforcing or resisting awards. Clients engage our international arbitration law firm for institutional cases before the ICC, ICDR, LCIA and SIAC as well as ad hoc UNCITRAL proceedings, and as international disputes lawyers we coordinate related court litigation when a dispute crosses forums.

Transnational Matters is an international arbitration and cross-border disputes law firm representing multinational corporations, non-governmental organizations, investors, States, and individuals in arbitral fora around the world, including:

Our firm is known for providing strategic representation combined with skilled negotiation through all aspects.

You have just received a Request for Arbitration. What happens next?

The clock is already running. Under most institutional rules the respondent’s first written reply is due within weeks, not months: 30 days from receipt of the Request under the ICC Rules (2021, Article 5), 28 days from the Commencement Date under the LCIA Rules (2020, Article 2), 30 days under the ICDR Rules (2021, Article 3), 14 days under the SIAC Rules (2025, Rule 7), and 30 days from receipt of the Notice under the UNCITRAL Rules (Article 4). Extensions are possible but must be requested before the deadline, and the first reply is also where a respondent nominates an arbitrator, objects to jurisdiction, and states any counterclaim. Positions not raised then are harder to raise later.

In the first two weeks we do four things: read the arbitration agreement and the governing rules to confirm whether the claimant has actually invoked them correctly; check whether the tribunal has jurisdiction over you and over every claim; secure the documents and witnesses that will decide the case before they move; and set a budget and a procedural strategy, including whether an expedited track, bifurcation, or an early settlement approach is in your interest (our arbitration cost calculator gives a first view of institutional fees). If the claimant has sought emergency relief, the timetable is shorter still and we respond the same day.

Transnational Matters acts as counsel for respondents and claimants in ICC, ICDR, LCIA, SIAC and UNCITRAL proceedings and in treaty cases before ICSID, from our Miami office, in English, Spanish and French. Book a 30-Minute Case Assessment or call 305.417.9866.

You hold an arbitral award. How do you collect in the United States?

An award is not money until a court recognizes it where the debtor’s assets are. In the United States, a foreign or non-domestic award is confirmed under Chapter 2 of the Federal Arbitration Act, which implements the New York Convention: the federal district courts have original jurisdiction (9 U.S.C. § 203), the action must be brought within three years after the award is made (9 U.S.C. § 207), and the court must confirm unless the award debtor proves one of the limited grounds in Article V of the Convention. A confirmed award becomes a United States judgment, enforced through writs of execution, garnishment and post-judgment discovery under federal and Florida procedure, including Florida’s proceedings supplementary (Fla. Stat. § 56.29). Our guide to enforcing foreign judgments and awards walks through the procedure.

Three points decide most enforcement cases in Florida and the Eleventh Circuit. First, where the award was seated: for awards made in the United States, the Eleventh Circuit now applies the vacatur grounds of 9 U.S.C. § 10, and a motion to vacate must be served within three months after the award is filed or delivered (9 U.S.C. § 12; Corporación AIC, S.A. v. Hidroeléctrica Santa Rita S.A., 66 F.4th 876 (11th Cir. 2023) (en banc)). Second, who the debtor is: an award against a foreign state or state-owned entity is enforced through the arbitration exception to the Foreign Sovereign Immunities Act (28 U.S.C. § 1605(a)(6)), but execution is limited to property used for commercial activity in the United States and generally requires a separate court order (28 U.S.C. § 1610). Third, where the assets are: bank accounts, receivables, real estate and shareholdings in Florida are reached through different writs on different timetables, and asset tracing often starts before the confirmation petition is filed.

We handle recognition, confirmation, defenses to enforcement, and asset execution as one engagement, and we act as Florida and Eleventh Circuit counsel for law firms abroad whose clients need to enforce or resist an award here. Our guide to enforcing an arbitration award in Florida compares the federal and state court routes and the deadlines that go with each. For treaty awards against states, see our Investment Protection practice. Book a 30-Minute Case Assessment or call 305.417.9866.

Transnational Matters: A Global International Arbitration Law Firm

We focus on practical legal solutions for international disputes. Our firm is dedicated to navigating the complexities of global arbitration and litigation, setting us apart with our deep understanding of diverse legal systems and cultures. From our Florida offices in West Palm Beach, Miami, and Coral Springs, we serve a broad spectrum of clients across key global markets, from multinational corporations to sovereign states. Our multilingual team, extensive experience in high-stakes cases, and commitment to achieving client objectives efficiently make us a preferred choice for cross-border legal challenges.

What Are the Benefits of International Arbitration?

A key advantage is its flexibility. Unlike national court systems, which involve complex procedural rules and legal machinations, the parties tailor the arbitration process to their specific needs and priorities. For example, the parties can choose the:

Place of arbitration
Number of arbitrators
Language to be used
Rules of procedure to be followed

Another benefit is that international arbitration is confidential. Unlike public court proceedings, arbitration hearings are held in private. This can be particularly important for businesses that must keep confidential and sensitive information from the public record.

It also benefits individuals who wish to avoid the public scrutiny that comes with a court case. It is also quicker and more cost-effective as court cases often take years to resolve as litigation costs quickly mount. By contrast, this is typically completed within months at a significantly lower cost.

One of the main advantages of international arbitration is the enforceability of arbitral awards. In many cases, the parties have entered into an agreement that includes a provision for enforcing an award. If one party fails to comply with the award, the other party can seek to have it enforced by the courts. This is particularly valuable for parties operating across multiple jurisdictions because it provides a dispute resolution method recognized and enforced in many countries.

In short, this is an attractive option for investors, States, businesses, and individuals. It provides a flexible, confidential, and efficient process for resolving disputes, which can be particularly useful for those who operate across multiple jurisdictions. Ultimately, navigating the process takes the advice and counsel of a skilled international arbitration attorney.

Meet The Transnational Matters International Arbitration Team

Our team is our greatest asset. Led by Davy Aaron Karkason, our attorneys possess extensive experience in international law and arbitration. Our global network includes experts like Alexandra Pagan Garcia, and Kevin Liu, who bring deep knowledge from their respective jurisdictions. We ensure comprehensive, high-quality legal services, supported by skilled professionals like COO Debbie Margarita and law clerk Christina Wittmeier. Our collective expertise and commitment to excellence set us apart in resolving complex international disputes.

How Our International Arbitration Law Firm Can Help

We concentrate our practice on international arbitration, providing critical support by navigating the complexities of cross-border disputes. We have comprehensive expertise in drafting effective dispute resolution clauses and managing the entire arbitration process under various international rules (e.g., ICC, LCIA, ICSID). Transnational Matters represents clients in high-stakes disputes involving commercial or investment treaties, ensuring an impartial and enforceable outcome. Our global presence and multilingual team allow us to handle cases involving multiple jurisdictions and legal systems, providing tailored strategies that align with our client’s objectives.

To successfully represent a client in an international arbitration process, we take several key steps:

1. Initial Assessment: Evaluate the dispute’s merits, jurisdictional issues, and applicable arbitration agreements.

2. Selecting Arbitrators: Choose impartial and experienced arbitrators suitable for the case.

3. Drafting and Filing Claims: Prepare and submit a detailed statement of claim outlining the case’s facts and legal grounds.

4. Procedural Planning: Establish a clear procedural framework, including timelines and rules for evidence submission.

5. Discovery and Evidence: Gather and exchange relevant documents, witness statements, and expert reports.

6. Hearings: Present the case through oral arguments, witness examinations, and expert testimonies.

7. Award and Enforcement: Obtain the arbitral award and, if necessary, pursue its enforcement across relevant jurisdictions.

We provide expertise in each step, ensuring strategic and efficient dispute resolution.

Why Choose Transnational Matters Over Other International Arbitration Law Firms?

Because international arbitration is so complex and requires a deep understanding of both international law and the laws of the countries involved in the dispute, having the informed representation and bold global advocacy our firm provides is essential. You can depend on our international arbitration lawyers to help you navigate this complex legal landscape.

Why Miami counsel for an international arbitration

Miami is an established seat and hearing venue for disputes between Latin American, European and Asian parties, with institutional offices and hearing facilities in the city, including the ICDR. Florida has its own International Commercial Arbitration Act for international cases seated here, alongside the Federal Arbitration Act and the New York and Panama Conventions, and the federal courts in Florida regularly hear petitions to compel arbitration, to obtain discovery in aid of foreign proceedings, and to confirm or enforce foreign awards. Our founding attorney is admitted in Florida and in the Southern, Middle and Northern Districts of Florida, so an arbitration seated in Miami and any related court step can be handled by the same team. Foreign and out-of-state teams can read our guide to local counsel in a Florida-seated arbitration before they retain a Florida lawyer.

Counsel in ICC, ICSID, LCIA and CAA proceedings, including a first-chair ICC award of more than US$614,000 under Hong Kong law
Enforcement and challenge of foreign awards before Florida state and federal courts
Investor-State claims under bilateral investment treaties, with published commentary in ICLG Investor-State Arbitration 2027
Work in English, Spanish and French, with the time-zone overlap that Latin American and European counterparties expect

Jurisdictions we serve

From drafting well-conceived arbitration clauses to representing clients in institutional and ad hoc arbitral proceedings and helping to enforce and challenge arbitration awards, Transnational Matters represents clients in proceedings connected to jurisdictions around the world, including:

Miami
New York
Washington D.C.
Mexico City
Paris
Colombo (Sri Lanka)
The Hague
Geneva
Istanbul
Dubai
Shanghai
Bogota
London

In addition to these locations, we also have offices in the following cities:

Above all, we bring a deep understanding of cultural and linguistic differences to international arbitration, which can help bridge any communication gaps and ensure that all parties understand the legal issues involved in the dispute. Let us guide you through the entire process.

Frequently Asked Questions

How much does international arbitration cost?

Institutional fees scale with the amount in dispute, and counsel fees depend on complexity. We scope budgets at the outset and use staged budgets or fee caps where possible, so costs stay proportional to the claim. For institution-by-institution fees, expedited-track eligibility, and step-by-step procedures, use our arbitration cost calculator.

Is arbitration better than litigation for cross-border disputes?

Arbitration usually wins on enforceability, neutrality, and confidentiality across borders. However, litigation can be faster against domestic counterparties with local assets. We recommend the forum only after mapping where the money is.

Can a foreign arbitral award be enforced in the United States?

Yes. Under the New York Convention, courts confirm foreign awards unless narrow defenses apply. We handle recognition, confirmation, and asset execution as part of the same engagement.

Contact Our International Arbitration Attorneys

If you are considering international arbitration, turn to Transnational Matters. You can depend on us to explain the process, assess the strengths and weaknesses of your case, and work to achieve the best possible outcome. Contact us today to get started.

Based in South Florida? Meet our international arbitration lawyers in Miami.

How long does an international arbitration take?

Most international commercial arbitrations conclude within roughly one to two years from constitution of the tribunal to a final award, though complex or multi-party matters can take longer, and investor–State cases often run three to five years. Institutional expedited procedures can shorten the schedule for smaller disputes. The realistic timeline for any given case depends on the arbitration agreement, the institution’s rules, the tribunal’s availability, and whether interim measures, challenges, or enforcement proceedings follow. We provide a case-specific assessment at the outset of an engagement.

Can I bring an arbitration against a foreign government?

Sometimes. A claim against a sovereign generally requires its consent to arbitrate — most commonly through an investment treaty, an investment chapter of a trade agreement, a domestic investment law, or an arbitration clause in a State contract. Whether a viable path exists depends on your nationality, how the investment is structured, and the instrument’s specific terms, and enforcing an award against sovereign assets raises separate immunity questions. This is a case-by-case legal analysis, not a foregone conclusion; our Investment Protection practice evaluates these questions before any filing.

Do I need a Florida lawyer if my arbitration is seated abroad?

Not always, but often it helps. Many arbitrations seated in London, Paris, Geneva or Singapore involve a party, assets, witnesses or evidence located in Florida or elsewhere in the United States. U.S. counsel can seek discovery in aid of the foreign proceeding where available, advise on how the award will later be recognized here, and coordinate with the lead team at the seat. We regularly act as sole counsel, as co-counsel with foreign firms, and as U.S. enforcement counsel after an award is rendered.

What should I prepare before a case assessment?

The contract or treaty containing the arbitration clause, any notice or request for arbitration you have sent or received, the key correspondence showing how the dispute arose, and a realistic view of the amount in dispute and your timing. If you are not ready for a call, our case assessment questionnaire walks through these points and lets us review your matter before we speak.