Choosing Turkey as the Seat of International Arbitration

Choosing the seat of arbitration is one of the most important decisions in an international commercial contract. The seat determines the legal jurisdiction to which the arbitration belongs, the procedural law governing the proceedings and the national courts that may support or supervise the arbitral process.

For contracts connected with Europe, Central Asia, the Middle East, the Balkans, the Caucasus and the Eastern Mediterranean, Turkey may be considered as a potential seat of international arbitration. Istanbul is particularly relevant because it provides access to Turkish arbitration law, specialised commercial courts, the Istanbul Arbitration Centre and a developing community of arbitration practitioners.

However, selecting Turkey as the seat should not be treated as a purely geographical or logistical choice. The parties must understand the consequences of applying Turkish arbitration legislation, the powers of Turkish courts, the available interim remedies, the statutory time limit for rendering an award, the annulment procedure and the international enforceability of the resulting award.

The principal legal instrument governing international arbitration seated in Turkey is International Arbitration Law No. 4686. The law applies where a dispute contains a foreign element and Turkey has been selected as the seat. It may also apply where its provisions are chosen under the conditions established by the legislation.

This article explains the meaning of the arbitral seat, the Turkish legal framework, procedural advantages, court assistance, tribunal powers, annulment risks, enforcement consequences and practical drafting considerations relevant to choosing Turkey as the seat of international arbitration.

What Is the Seat of Arbitration?

The seat of arbitration is the legal home of the proceedings. It establishes the jurisdictional connection between the arbitration and a particular national legal system.

The seat ordinarily determines:

• The procedural arbitration law, also known as the lex arbitri;
• The courts authorised to assist the arbitration;
• The courts authorised to hear an application to set aside the award;
• Mandatory procedural rules;
• Certain requirements concerning tribunal constitution and due process;
• The legal nationality of the arbitral award;
• The framework under which the award may be challenged.

The seat is not necessarily the place where hearings physically take place. An arbitration may be legally seated in Istanbul while hearings are conducted in London, Paris, Dubai, Ankara or entirely through video conference.

Article 9 of the Turkish International Arbitration Law expressly permits the parties or their selected arbitration institution to determine the seat. It also permits the tribunal to meet elsewhere where the requirements of the proceedings make this appropriate, provided that the parties receive prior notice.

Accordingly, choosing Istanbul as the seat does not require every witness, arbitrator, expert or lawyer to travel to Istanbul for each procedural step.

Seat, Institution, Hearing Venue and Governing Law Are Different Concepts

International contracts sometimes confuse the seat of arbitration with the institution administering the case, the physical hearing venue or the substantive law governing the contract.

These concepts must be distinguished.

Seat of Arbitration

The seat determines the procedural legal system and supervisory courts. For example:

“The seat of arbitration shall be Istanbul, Türkiye.”

Arbitration Institution

The institution administers the proceedings under its rules. For example:

“The arbitration shall be administered by the Istanbul Arbitration Centre under the ISTAC Arbitration Rules.”

ISTAC’s official model clause advises parties to specify the place of arbitration separately from the institution, language, number of arbitrators and law applicable to the merits.

Hearing Venue

The hearing venue is where a meeting or evidentiary hearing physically occurs. It does not necessarily alter the legal seat.

Governing Law

The governing law regulates the parties’ substantive contractual rights and obligations.

A contract may therefore provide that:

• The seat is Istanbul;
• The institution is ISTAC;
• The hearing is conducted online;
• The language is English;
• The substantive governing law is English, Swiss or Turkish law.

Selecting Turkey as the seat does not automatically mean that Turkish substantive law governs the contract. Article 12 of Law No. 4686 permits the tribunal to decide the merits according to the rules of law selected by the parties. A reference to the law of a state is generally treated as a reference to its substantive law rather than its conflict-of-laws or procedural rules unless otherwise agreed.

The Turkish International Arbitration Law

International Arbitration Law No. 4686 was adopted on 21 June 2001 and published in the Official Gazette on 5 July 2001. Its purpose is to regulate the principles and procedures applicable to international arbitration.

The law contains provisions concerning:

• Foreign elements;
• Arbitration agreements;
• Judicial intervention;
• Interim measures;
• Appointment and challenge of arbitrators;
• Tribunal jurisdiction;
• Procedural autonomy;
• The seat and language of arbitration;
• Evidence and expert examination;
• Applicable substantive law;
• The form and content of awards;
• Correction and interpretation;
• Setting-aside proceedings;
• Arbitration costs.

The law adopts a system based substantially on party autonomy. Subject to mandatory requirements, the parties may determine the rules governing the proceedings directly or by referring to national, international or institutional arbitration rules. In the absence of an agreement, the tribunal conducts the proceedings under Law No. 4686.

When Does a Dispute Have a Foreign Element?

The Turkish International Arbitration Law applies primarily to disputes containing a foreign element where Turkey is selected as the seat.

Under Article 2, a foreign element may exist where:

• The parties have domiciles, habitual residences or places of business in different states;
• The seat is located in a state different from the parties’ relevant places of business;
• A substantial part of the contractual obligations will be performed in another country;
• The place most closely connected to the dispute is in another state;
• Foreign capital has been introduced into a company connected with the principal agreement;
• Foreign credit or guarantee arrangements are required;
• The underlying transaction results in the movement of goods or capital between countries.

An arbitration may therefore be considered international even where both contracting parties are incorporated in Turkey. A contract involving foreign investment, international financing, cross-border deliveries or movement of capital may satisfy the foreign-element requirement.

Where no foreign element exists, the domestic arbitration provisions of the Turkish Code of Civil Procedure may apply instead.

Party Autonomy under Turkish Arbitration Law

A significant consideration when choosing Turkey as the seat is the broad degree of procedural autonomy granted to the parties.

The parties may generally determine:

• The arbitration institution;
• The applicable procedural rules;
• The number of arbitrators;
• The appointment procedure;
• The qualifications of arbitrators;
• The language of the proceedings;
• The substantive governing law;
• The timetable for submissions;
• Evidence procedures;
• The availability of hearings;
• Confidentiality arrangements;
• The allocation of costs.

Article 8 of Law No. 4686 allows the parties to establish procedural rules directly or by referring to institutional or international arbitration rules. It also requires equal treatment and a genuine opportunity for each party to present its claims and defences.

This flexibility means that Turkey may be selected as the seat even where the parties prefer proceedings conducted in accordance with the rules of an international arbitration institution.

The choice of Turkey as the seat does not require the use of ISTAC. Parties may select another recognised institution or agree on ad hoc arbitration. Nevertheless, the institutional rules and Turkish mandatory procedural law must be compatible.

Limited Court Intervention

Another relevant feature of Turkish international arbitration law is the principle of limited judicial intervention.

Article 3 provides that Turkish courts may intervene in international arbitration only in the circumstances permitted by Law No. 4686.

Court involvement may nevertheless be required for matters including:

• Appointment of arbitrators where the agreed procedure fails;
• Challenge or removal of arbitrators;
• Interim injunctions and attachments;
• Collection of evidence;
• Extension of the arbitration period;
• Setting aside the arbitral award;
• Issuance of an enforceability certificate.

Following the amendments made by Law No. 7101, functions assigned under Law No. 4686 are performed by a civil or commercial court of first instance depending on the subject matter of the dispute. Applications to set aside an international arbitral award are filed directly before the territorially competent Regional Court of Appeal.

The distinction between supportive and supervisory court functions should be considered when selecting Turkey as the seat. Turkish courts may assist the arbitration without assuming general authority to reconsider the merits.

Judicial Assistance with the Appointment of Arbitrators

The parties are free to determine the number and appointment method of arbitrators, but the number must be odd. If the parties do not specify the number, the statutory default is three arbitrators.

Turkish courts may assist where:

• A party fails to appoint an arbitrator;
• Party-appointed arbitrators cannot agree on the presiding arbitrator;
• An appointing authority fails to perform its role;
• The agreed appointment mechanism becomes unworkable.

When making an appointment, the court must consider the parties’ agreement, the arbitrator’s independence and impartiality and, in international cases, nationality-related neutrality considerations prescribed by the law.

The availability of judicial assistance reduces the risk that the arbitration will fail entirely because one party refuses to cooperate with tribunal formation.

However, parties selecting Turkey as the seat should still draft a workable appointment clause. Reliance on court assistance should be a fallback rather than the primary mechanism.

Independence and Impartiality of Arbitrators

Turkish arbitration law requires a person approached for appointment to disclose circumstances that may create justified doubts regarding independence or impartiality.

The disclosure obligation continues after appointment. An arbitrator may be challenged where the arbitrator lacks agreed qualifications, a contractual challenge ground exists or circumstances create justified doubts regarding neutrality.

The parties may agree on their own challenge procedure, including by selecting institutional rules. If a challenge is rejected by the tribunal, the challenging party may seek judicial review within the applicable statutory period.

For parties considering Turkey as the seat, the existence of a statutory challenge framework provides a judicial safeguard while preserving the parties’ freedom to select specialist arbitrators.

Interim Measures and Asset Protection

The availability of effective interim protection is a central consideration when selecting an arbitral seat.

Article 6 of Law No. 4686 permits a party to request an interim injunction or interim attachment from a Turkish court before or during the arbitration. A court application for provisional relief does not violate or waive the arbitration agreement.

Unless the parties agree otherwise, the tribunal may also issue interim measures and may require appropriate security. However, tribunal powers are subject to important limitations. An arbitral tribunal cannot issue a measure that:

• Requires compulsory execution by state enforcement authorities;
• Requires another public authority to act;
• Directly binds a third party.

Consequently, court assistance may be necessary to freeze a Turkish bank account, register a restriction, seize property or bind a third-party custodian.

Where a party fails to comply with a tribunal-ordered measure, the opposing party may request assistance from the competent Turkish court.

A party that obtains a judicial interim injunction or attachment before commencing arbitration must initiate the arbitration within 30 days. Otherwise, the provisional measure automatically terminates.

These provisions make Turkey particularly relevant where the opposing party or commercially important assets are located within Turkish jurisdiction.

Institutional Support through ISTAC

The Istanbul Arbitration Centre offers institutional arbitration services for domestic and international disputes.

ISTAC provides:

• Standard arbitration;
• Fast-track proceedings;
• Emergency arbitrator proceedings;
• Institutional appointment support;
• Published cost rules;
• Model arbitration clauses;
• Online hearing procedures.

Its official model clause provides that disputes arising out of or connected with a contract may be finally resolved under the ISTAC Arbitration Rules. ISTAC recommends that parties specify the place of arbitration, language, number of arbitrators and law applicable to the merits.

Choosing Istanbul as the seat and ISTAC as the institution may provide a coherent legal and administrative structure. Turkish arbitration law supplies the lex arbitri, while ISTAC administers the proceedings under its institutional rules.

However, choosing Istanbul as the seat does not require parties to select ISTAC. Similarly, choosing ISTAC does not automatically determine the legal seat. The contract should address each matter expressly.

Language of Arbitration

Law No. 4686 permits arbitration proceedings to be conducted in Turkish or in an official language of a state recognised by the Republic of Türkiye.

The parties are free to determine the language or languages. If they do not, the tribunal makes the determination. The selected language generally applies to pleadings, hearings, procedural decisions, the final award and written communications. The tribunal may require translations of documents.

International arbitration seated in Turkey may therefore be conducted in English.

The choice of language should take account of:

• The language of the contract;
• The language of contractual correspondence;
• Witnesses’ language;
• The governing substantive law;
• Translation costs;
• The qualifications of potential arbitrators;
• The location of enforcement proceedings.

Although the arbitration itself may be conducted in English, applications before Turkish courts will ordinarily require Turkish-language submissions and certified translations of relevant foreign-language documents.

Representation by Foreign Counsel

Law No. 4686 permits parties to be represented in arbitration proceedings by foreign natural or legal persons.

However, the statutory provision states that this rule does not extend to applications made before Turkish courts in connection with the arbitration.

Accordingly, a foreign party may use international arbitration counsel during the arbitral proceedings but will generally require appropriately authorised Turkish counsel for court applications such as:

• Interim injunction proceedings;
• Arbitrator appointment applications;
• Challenge proceedings;
• Evidence-assistance requests;
• Setting-aside litigation;
• Enforcement-related applications.

For complex disputes, coordination between international arbitration counsel and Turkish court counsel should be planned at an early stage.

Evidence, Experts and Hearings

The tribunal may hold oral hearings or decide the case on the documents, depending on the parties’ agreement and the circumstances.

Unless the parties have agreed that no hearing will be held, the tribunal must hold a hearing at an appropriate stage when one party requests it. The parties must receive appropriate advance notice of hearings, inspections, expert examinations and evidence-related meetings. Submissions, information and documents presented to the tribunal must also be communicated to the opposing party.

The tribunal may appoint one or more experts, require the parties to provide information and documents to those experts and order inspections. It may also seek assistance from a Turkish court for the collection of evidence.

These provisions may be particularly useful in disputes involving:

• Construction and engineering;
• Energy;
• Accounting and valuation;
• Manufacturing defects;
• Technology systems;
• International trade;
• Banking and finance.

ISTAC’s online hearing rules also permit hearings and meetings to be conducted through video conference or teleconference. The tribunal may establish technical, security and confidentiality arrangements after consulting the parties and must make reasonable efforts to preserve the right to be heard.

The Default One-Year Arbitration Period

A distinctive feature of Turkish international arbitration law is the statutory period for rendering an award.

Unless the parties agree otherwise, the tribunal must issue its decision on the merits within one year from:

• Appointment of the sole arbitrator; or
• Preparation of the minutes of the tribunal’s first meeting in a multi-member case.

The parties may extend this period by agreement. If they cannot agree, a party may apply to the competent Turkish court for an extension.

This rule may promote procedural discipline, but it also creates a risk in complex proceedings. An award issued after expiry of the applicable arbitration period may be challenged.

Parties selecting Turkey as the seat should therefore consider modifying the default rule in the arbitration clause or ensuring that the institutional rules and procedural timetable provide an effective extension mechanism.

For a high-value construction, energy or corporate dispute, an unmodified one-year period may be difficult where the proceedings involve extensive document production, multiple experts and a lengthy evidentiary hearing.

Applicable Substantive Law

Selecting Turkey as the seat does not prevent the parties from choosing another substantive law.

Under Article 12 of Law No. 4686, the tribunal decides the dispute according to the contract and the rules of law selected by the parties. Commercial customs and usages connected with the selected law may also be considered.

Where the parties have not selected the applicable law, the tribunal applies the substantive rules of the state with which the dispute is most closely connected.

The tribunal may decide according to equity or act as an amiable compositeur only where the parties expressly authorise it to do so.

The arbitration clause should therefore distinguish clearly between:

• The law governing the principal contract;
• The law governing the arbitration agreement;
• The procedural law resulting from the seat.

A transaction may use Turkish arbitration law as the lex arbitri while applying another jurisdiction’s substantive law to the merits.

Form and Content of the Arbitral Award

An award issued in an arbitration seated in Turkey must contain the information prescribed by Law No. 4686.

This includes:

• Identification of the parties and representatives;
• The legal grounds and reasoning;
• The amount awarded in compensation claims;
• The seat and date of the award;
• The names and signatures of the arbitrators;
• Any dissenting opinions;
• A statement indicating that the award may be subject to a setting-aside action.

Unless the parties agree otherwise, the tribunal may issue partial awards.

The parties may also request correction of material errors, interpretation of part or all of the award and an additional award regarding claims raised but not decided. The statutory period for such applications is generally 30 days from notification.

Setting Aside an Award Seated in Turkey

By choosing Turkey as the seat, the parties accept that Turkish courts will exercise supervisory jurisdiction over an application to set aside the award.

Following the amendments introduced by Law No. 7101, the setting-aside action is filed directly before the Regional Court of Appeal having territorial jurisdiction over the location of the competent first-instance court. The case is to be handled with priority and urgency.

The setting-aside action is not a general appeal on the merits.

An applicant may rely on limited grounds including:

• Incapacity of a party;
• Invalidity of the arbitration agreement;
• Improper tribunal constitution;
• Failure to issue the award within the arbitration period;
• An unlawful jurisdictional decision;
• Decisions outside the arbitration agreement;
• Failure to decide the entire claim;
• Excess of authority;
• Material procedural violations;
• Failure to respect equality between the parties.

The court must also examine whether the dispute is arbitrable under Turkish law and whether the award violates Turkish public policy.

A setting-aside action must generally be filed within 30 days from notification of the award or the relevant correction, interpretation or additional award decision. Filing the action automatically suspends enforcement of the award under the statutory regime.

The Regional Court of Appeal’s decision may be challenged before the Court of Cassation under the applicable provisions of the Turkish Code of Civil Procedure.

International Enforcement of a Turkish-Seated Award

An award rendered in an arbitration legally seated in Turkey will ordinarily be treated internationally as a Turkish arbitral award.

Where enforcement is sought in another country, the award may benefit from the New York Convention if the enforcement jurisdiction is a contracting state and the Convention’s requirements are satisfied.

As of July 2026, the United Nations Treaty Collection records 172 parties to the New York Convention. The Convention seeks to provide common legal standards for the recognition of arbitration agreements and the recognition and enforcement of foreign or non-domestic arbitral awards.

Turkey applies the Convention on the basis of reciprocity to awards made in another contracting state. Its declaration also limits application to disputes arising from relationships regarded as commercial under Turkish law.

The enforcement court in another country may refuse recognition only on the limited grounds established by the Convention, such as:

• Invalidity of the arbitration agreement;
• Lack of proper notice;
• Inability to present the case;
• Excess of jurisdiction;
• Irregular tribunal constitution or procedure;
• The award not being binding;
• Annulment or suspension at the seat;
• Non-arbitrability;
• Public policy.

The possibility of international enforcement is one of the principal legal reasons for selecting a seat in a New York Convention jurisdiction.

Potential Advantages of Choosing Turkey as the Seat

Turkey may offer several potential advantages depending on the transaction.

A Defined International Arbitration Statute

Law No. 4686 provides a specific statutory framework for international arbitration, addressing the process from the arbitration agreement and tribunal constitution through the issuance and challenge of the award.

Procedural Autonomy

The parties may select institutional rules, determine tribunal composition, choose the language and designate the substantive governing law.

Access to Interim Protection

Turkish courts may issue interim injunctions or attachments in support of arbitration, while the tribunal may grant measures directed at the parties within its statutory authority.

Institutional Infrastructure

ISTAC offers standard arbitration, emergency arbitrator procedures, fast-track mechanisms and online hearing procedures.

English-Language Proceedings

The parties may agree to conduct the arbitration in English, even though Turkish will generally be required for court proceedings connected with the arbitration.

International Enforceability

Awards seated in Turkey may benefit from the New York Convention when enforcement is sought in other contracting states.

Risks and Points Requiring Careful Drafting

Choosing Turkey as the seat also involves issues that should be addressed at the contract stage.

The One-Year Default Period

The statutory one-year period may be unsuitable for complex disputes unless the parties modify it or establish an effective extension process.

Automatic Stay Following a Setting-Aside Action

Filing an annulment action automatically suspends enforcement under Law No. 4686. This may affect the award creditor’s recovery timetable.

Turkish-Language Court Proceedings

Although the arbitration may be conducted in English, Turkish court submissions will require Turkish-language documents and, where appropriate, certified translations.

Arbitrability Restrictions

Disputes concerning rights in rem over immovable property located in Turkey and matters that are not subject to the parties’ free disposition fall outside the scope of the International Arbitration Law.

Need for Precise Institutional Drafting

A clause should not confuse the seat, institution, hearing location and substantive governing law. ISTAC’s model clause expressly treats these as separate matters.

Court Assistance May Be Necessary

Tribunal-ordered measures cannot directly bind third parties or compel public authorities. Judicial relief may be necessary where bank accounts, registries or third-party assets are involved.

Sample Clause Selecting Turkey as the Seat

The following clause may be used as a starting point for an international contract:

“Any dispute, controversy or claim arising out of or relating to this agreement, including its negotiation, formation, existence, validity, interpretation, performance, breach, termination or the consequences of termination, shall be finally resolved by arbitration administered by the Istanbul Arbitration Centre in accordance with the ISTAC Arbitration Rules in force on the date the arbitration is commenced.

The seat of arbitration shall be Istanbul, Türkiye. The tribunal shall consist of three arbitrators. The language of arbitration shall be English. The agreement shall be governed by Turkish substantive law, and the arbitration agreement contained in this clause shall be governed by Turkish law.

Nothing in this clause shall prevent a party from applying to an emergency arbitrator or a competent court for urgent interim or conservatory relief. Such an application shall not constitute a waiver of the arbitration agreement.

The parties may agree in writing to extend the statutory arbitration period. The tribunal shall be authorised to issue partial, interim and final awards.”

The clause should be adapted to the transaction. A sole arbitrator may be more suitable for lower-value disputes, while a different substantive law may be appropriate for a multinational transaction.

Practical Checklist before Selecting Turkey

Before choosing Turkey as the seat, the parties should consider:

• Whether the transaction contains a foreign element;
• Whether the dispute is arbitrable under Turkish law;
• Which institution will administer the case;
• Whether Istanbul or another Turkish city will be the seat;
• Whether the proceedings will be conducted in English;
• Whether a sole arbitrator or three-member tribunal is appropriate;
• How arbitrators will be appointed;
• Whether emergency arbitrator rules should apply;
• Whether Turkish court interim measures may be required;
• Whether the one-year statutory period should be modified;
• Which substantive law will govern the contract;
• Which law will govern the arbitration agreement;
• Where the counterparty’s assets are located;
• Whether enforcement is likely to be sought under the New York Convention;
• Whether foreign and Turkish counsel will need to cooperate;
• Whether confidentiality should be regulated expressly;
• Whether related contracts contain consistent dispute-resolution provisions.

Frequently Asked Questions

Is Istanbul the only possible seat in Turkey?

No. The parties may select another city in Turkey. Istanbul is frequently considered because of its commercial significance and the presence of ISTAC, but the legal seat may be another agreed location.

Does choosing Turkey as the seat require Turkish law to govern the contract?

No. The parties may select another substantive law. The seat and governing law perform different functions.

Can the arbitration be conducted in English?

Yes. The parties may select English as the arbitration language under Law No. 4686.

Must the parties select ISTAC?

No. Turkey may be selected as the seat while another institution administers the arbitration or while the arbitration proceeds on an ad hoc basis.

Can hearings take place outside Turkey?

Yes. The tribunal may meet elsewhere without changing the legal seat. ISTAC proceedings may also use online hearings.

Can Turkish courts grant interim relief?

Yes. A party may request an interim injunction or attachment before or during arbitration without waiving the arbitration agreement.

How long does the tribunal have to issue the award?

Unless the parties agree otherwise, the statutory default is one year from the appointment of the sole arbitrator or the first meeting record of a multi-member tribunal.

Which court hears a setting-aside action?

The application is filed directly before the territorially competent Regional Court of Appeal.

What is the deadline for setting aside an award?

The application must generally be filed within 30 days from notification of the award or the relevant post-award decision.

Does an annulment case suspend enforcement?

Yes. Filing the setting-aside action automatically suspends enforcement under Article 15 of Law No. 4686.

Can an award seated in Turkey be enforced abroad?

Yes. A Turkish-seated award may be recognised and enforced in another New York Convention state, subject to the Convention’s requirements and limited refusal grounds.

Conclusion

Choosing Turkey as the seat of international arbitration may provide parties with a structured legal regime, procedural autonomy, access to judicial assistance and institutional support through organisations such as the Istanbul Arbitration Centre.

The Turkish International Arbitration Law regulates the arbitration agreement, tribunal constitution, interim measures, procedural fairness, evidence, applicable law, awards and setting-aside proceedings. It also restricts judicial intervention to the circumstances authorised by legislation.

Turkey may be particularly relevant where the transaction, project, parties or assets are connected with the country or surrounding commercial regions. Istanbul may also offer practical benefits for disputes involving Turkish law, Turkish companies, infrastructure projects, energy transactions, construction contracts, international trade or corporate investments.

Nevertheless, the selection requires careful drafting.

The parties should distinguish the seat from the institution, hearing venue and governing law. They should address the language, tribunal structure, appointment procedure, emergency relief and statutory arbitration period. They should also consider the automatic suspension resulting from a setting-aside action and the need for Turkish counsel in court-related proceedings.

No arbitral seat is appropriate for every transaction. The decision should be based on the contract’s value, complexity, governing law, location of evidence, nationality of the parties, potential interim measures and countries in which the award may need to be enforced.

When these factors support the choice, Turkey can provide a legally defined and internationally connected framework for commercial arbitration. The most effective approach is to assess the seat at the contract-negotiation stage and draft the arbitration agreement specifically for the transaction rather than relying on generic boilerplate language.

Legal Disclaimer: This article is provided for general informational purposes only and does not constitute legal advice. Arbitration legislation, institutional rules and judicial practice may change. The appropriate seat depends on the parties, contract, governing law, nature of possible disputes and intended enforcement jurisdictions. Transaction-specific legal advice should be obtained before executing an arbitration agreement.