*4.3.6 Implementation of a decision*

The Rules allow the arbitral tribunal to implement its decision "on-chain" using a private key. This means the tribunal has the power to make changes to the smart

contract as per its decision, which may reverse a transaction or allow the transaction to continue and makes changes to the digital assets. No additional steps are required to enforce the decision. Furthermore, the right to appeal under the Arbitration Act 1996 is specifically removed. It is debatable whether such a fast-track procedure with no appeal right meets the requirement of natural justices.

#### *4.3.7 Enforcement of award*

Given the applicable law is under English law, an award can be enforced through the court proceedings in England and Wales The multi-jurisdiction nature of blockchain makes the enforcement via the New York Convention attractive. However, the enforcement of a foreign award may be refused because the local legislation rules that matters relating to digital assets as illegal on the ground of public policy. Parties are advised to check the status of local law from time to time as a measure to manage such risks.

#### **4.4 The way forward**

To date, the Rules are untried with perceived uncertainties. It is only a matter of time before the first case is tested. This area of law will continue to develop, mature, and refine. The release of the Rules by UKJT, a UK government-backed body, represents the first significant step toward making progress in the resolution of digital disputes.
