I INTRODUCTION: THE SHORTCOMINGS OF A TWO-TIER CONTROL CONCEPTION OF INTERNATIONAL COMMERCIAL ARBITRATION - II NO PRIMARY CONTROL JURISDICTION OF THE COURTS OF THE SEAT UNDER THE NEW YORK CONVENTION - III THE RECOGNITION OF FOREIGN VACATUR JUDGMENTS UNDER DOMESTIC RULES: AN ALTERNATIVE LEGAL BASIS FOR A PRIMARY CONTROL SYSTEM? - IV PRIMARY JURISDICTION CONTROL AND POLICY OPTIONS - V THE IMPORTANCE OF SUPERVISORY-SUPERVISORY JURISDICTION - VI CONCLUSION: THE PROPER BALANCE OF THE RESPECTIVE ROLES OF ARBITRATION AND OF THE STATE OF THE SEAT