arbitrators under contractually granted powers=(1990, pp 145-146). But as the inclusion of >ord inarily= implies, there are situations in which enforcement is necessary to ensure compliance. In order to be a real alternative to court-ordered interim relief. the orders of the arbitrators must be fortified with a real threat of enforcement. To achieve this end, state support is needed Cross-border enforcement of arbitrator-granted interim relief is an important aspect of the enforcement issue with regard to international commercial arbitration. In the absence of an international regime for cross-border enforcement, a unilateral approach can be seen as a way to solve the problem. The New york Convention is silent on the question of interim measures of protection and their cross-border enforcement(Van den Berg, 1981, p. 144). The Supreme Court of Queensland(see Sanders, 1996, p 115)rejected an attempt to enforce an interim award under the New York Convention in 1993. Berger(1993, p. 345 with further reference)outlines the convincing arguments against the enforcement of interim measures of protection under the New York Convention. In a cross-border context. arbitrator-granted interim relief could become even more efficient than court -ordered relief if at least a unilateral enforcement regime is in place. The importance of cross-border enforcement will be illustrated below with regard to interim measures preventing the dissipation of assets An arbitration will often take place in a third, >neutral= country. This is a place where substantive assets of the parties are most likely not held. If an arbitrator orders interim relief, it is(with the exception of German law)-at best-only enforceable at the seat of arbitration. The effect of the provisional remed ies is therefore rather limited. It will not reach assets in the home countries of the parties. If a court at the seat of arbitration grants an interim order, it can only prevent the dissipation of assets out of its jurisdiction In the absence of a bilateral or multilateral enforcement agreement covering court ordered or arbitrator-granted interim relief, the jurisdictional limitations force an arbitration party to apply to courts in the country or even countries where the assets are held. This is the reason why it is so important to provide for court access even if the seat of arbitration is outside the country where the order is sought. Article 1(2)of the model law caters for this need. If interim relief in arbitration would be cross- border enforceable, one order would be sufficient and no need would arise to apply to several courts for an order under probably different regimes of interim relief. Only enforcement proceedings in different countries would be needed It is unlikely that a country enforces interim relief granted by a court of a foreign country without an agreement providing for reciprocity. To expect a global multilateral enforcement agreement for court-ordered interim relief is illusionary. To establish an international regime for the cross-border enforcement of arbitrator granted interim relief will be difficult to achieve. a possibility would be to amend the New York Convention. In the meantime, unilateral solutions could provide for cross border effectiveness in the sense that countries render their mechanisms for enforcing arbitrator-granted interim relief not only applicable if they are chosen as arbitration venue but also in the case that the seat of arbitration is somewhere outside the country This would reflect the legislator=s commitment to the cause of arbitration as a whole 4. Country reportsarbitrators under contractually granted powers= (1990, pp. 145-146). But as the inclusion of >ordinarily= implies, there are situations in which enforcement is necessary to ensure compliance. In order to be a real alternative to court-ordered interim relief, the orders of the arbitrators must be fortified with a real threat of enforcement. To achieve this end, state support is needed. Cross-border enforcement of arbitrator-granted interim relief is an important aspect of the enforcement issue with regard to international commercial arbitration. In the absence of an international regime for cross-border enforcement, a unilateral approach can be seen as a way to solve the problem. The New York Convention is silent on the question of interim measures of protection and their cross-border enforcement (Van den Berg, 1981, p. 144). The Supreme Court of Queensland (see Sanders, 1996, p. 115) rejected an attempt to enforce an interim award under the New York Convention in 1993. Berger (1993, p. 345 with further reference) outlines the convincing arguments against the enforcement of interim measures of protection under the New York Convention. In a cross-border context, arbitrator-granted interim relief could become even more efficient than court-ordered relief if at least a unilateral enforcement regime is in place. The importance of cross-border enforcement will be illustrated below with regard to interim measures preventing the dissipation of assets. An arbitration will often take place in a third, >neutral= country. This is a place where substantive assets of the parties are most likely not held. If an arbitrator orders interim relief, it is (with the exception of German law) - at best - only enforceable at the seat of arbitration. The effect of the provisional remedies is therefore rather limited. It will not reach assets in the home countries of the parties. If a court at the seat of arbitration grants an interim order, it can only prevent the dissipation of assets out of its jurisdiction. In the absence of a bilateral or multilateral enforcement agreement covering court￾ordered or arbitrator-granted interim relief, the jurisdictional limitations force an arbitration party to apply to courts in the country or even countries where the assets are held. This is the reason why it is so important to provide for court access even if the seat of arbitration is outside the country where the order is sought. Article 1(2) of the Model Law caters for this need. If interim relief in arbitration would be cross￾border enforceable, one order would be sufficient and no need would arise to apply to several courts for an order under probably different regimes of interim relief. Only enforcement proceedings in different countries would be needed. It is unlikely that a country enforces interim relief granted by a court of a foreign country without an agreement providing for reciprocity. To expect a global, multilateral enforcement agreement for court-ordered interim relief is illusionary. To establish an international regime for the cross-border enforcement of arbitrator￾granted interim relief will be difficult to achieve. A possibility would be to amend the New York Convention. In the meantime, unilateral solutions could provide for cross￾border effectiveness in the sense that countries render their mechanisms for enforcing arbitrator-granted interim relief not only applicable if they are chosen as arbitration venue but also in the case that the seat of arbitration is somewhere outside the country. This would reflect the legislator=s commitment to the cause of arbitration as a whole. 4. Country reports