AAA/ICDR Arbitrator's Award

Summary

This template is a draft award for an arbitrator or arbitrators in an American Arbitration Association (AAA) or International Centre for Dispute Resolution (ICDR) arbitration. This template includes practical guidance, drafting notes, and alternate clauses. An AAA/ICDR award must be in writing and signed by the arbitrators. AAA Commercial Arbitration Rules and Mediation Procedures (AAA Rules) Rule R-46(a); ICDR International Dispute Resolution Procedures, International Arbitration Rules (ICDR Rules) Art. 30. The award should state the date it was made and the place of arbitration. ICDR International Dispute Resolution Procedures, International Arbitration Rules Art. 30. If the award leaves open issues to resolve—for example, claims have been bifurcated or the issue of attorney's fees needs further hearing—identify the award as interim unless you have reasons why it must be deemed final. Identify the award as final only if you intend the time to begin to run for seeking judicial review of the award. Under ICDR Rules in particular, unless the parties agree otherwise, they expressly waive and forego any right to punitive, exemplary, or similar damages unless any applicable law requires that compensatory damages be increased in a specified manner. ICDR International Dispute Resolution Procedures, International Arbitration Rules Art. 31.5. For a listing of key content covering AAA Arbitration, see AAA Arbitration Resource Kit. For related templates, see AAA Demand for Arbitration, AAA Answer with Counterclaims, ICDR Notice of Arbitration, and ICDR Answer with Counterclaims. For a related flowchart, see AAA Commercial Arbitration Flowchart. For a related chart, see AAA, JAMS, FINRA, and CPR Dispositive Motion Rules Comparison Chart. For related practice notes, see AAA Expedited Arbitration Procedures, and AAA Dispositive Motions.