Interim measures are playing an increasingly important role in the international arbitration system. However, interim measures are plagued by two inter-related problems. First, this Note analyzes institutional rules and published arbitral case law to show that some arbitral tribunals have established lower standards for issuing interim measures relative to national courts. Second, this Note analyzes the national courts of the United States, Germany, and the United Kingdom to show the discordance among national courts in the enforcement of interim measures issued by a tribunal. This paper highlights the inter- related nature of these two problems, and proposes an international convention that harmonizes the enforcement of interim measures, while at the same time raising the standard necessary to issue interim measures.

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