The past three decades have seen a constant growth of international commercial arbitration in Latin America, with no end in sight. The region had traditionally been disinclined, if not outright hostile, to the concept of international arbitration.

Under the so-called Calvo doctrine (named after the Argentine diplomat and historian Carlos Calvo, 1824-1906), a state and by extension its citizens should not subject itself to a foreign jurisdiction — including international arbitral tribunals.

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