Before commencing the arbitration

• Consider any applicable limitation periods that affect when the arbitration needs to be commenced.

• Consider whether all claims that you wish to raise in UNCITRAL arbitration are covered by the arbitration agreement which refers the dispute to arbitration.

• Consider where the award may be enforced and whether any steps are required to protect assets, e.g., a freezing injunction.

• Consider the provisions for the appointment of the tribunal. If there are to be party-appointments than contact potential arbitrators to assess their suitability and availability and for them to confirm their independence.

• Start to collate all the evidence you are likely to need including preserving any electronic evidence that may be required.

Emergency measures

• Prior to the constitution of the arbitral tribunal, any request for interim measures would have to be made to the relevant court. In particular, consider applying to freeze or preserve assets that may be required to satisfy any award.