The Astana International Financial Center’s Court is a novel conflict determination effort aimed at attracting investors in the same way similar financial centers in the Persian Gulf have done with their courts and arbitration processes. This article contrasts and compares various approaches, focusing on aspects of private international law like jurisdiction, relevant law, and the admission and execution of judgments and arbitral awards. This research finds that the initiative’s success, particularly for junior courts, will be determined by its ability to create amicable relationships with the host country’s local courts.

It is critical to develop an Asian model of alternative conflict resolution that takes Asian traditions into account. Simply adopting Western standards will be less likely to accommodate Asians’ distinctive approach to conflict resolution. If international business mediation or arbitration is sensitive to cultural requirements and expectations, culture-related issues may be avoided.