These are Anrak's own institutional rules. They use the Federal Arbitration Act and applicable seat law as the legal baseline and current U.S. institutional practice as a benchmark. References to AAA materials are comparative only; Anrak is not authorized to administer AAA rules.
I. Scope and governing framework
Rule 1 — Application
These Rules apply only where parties have agreed in writing that Anrak will administer a business-to-business commercial dispute under the Anrak U.S. Commercial Arbitration Rules. The version in effect when a complete Demand is received applies unless the agreement fixes another Anrak version or mandatory law requires otherwise.
Rule 2 — Launch exclusions
Anrak will not accept under these Rules a consumer, employment or workplace, labor, transportation-worker, class, collective, representative, mass or coordinated filing, or a claim within the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act. The Center may require declarations and supporting contracts to classify the case. A refusal to administer under this Rule is not a merits or arbitrability decision.
Rule 3 — Definitions
“Center” means Anrak Arbitration Center. “Tribunal” means one or three appointed arbitrators. “Business day” excludes Saturday, Sunday and federal holidays at the seat. “Writing” includes a reproducible electronic record. “Seat” is the juridical place of arbitration, not a hearing venue. “Rules snapshot” means the immutable pack, seat overlay and case classification stored when the case is filed.
Rule 4 — Hierarchy and interpretation
Mandatory law at the seat prevails, followed by the parties' arbitration agreement, these Rules, procedural orders and Center practice notes. The Center interprets these Rules before constitution; the Tribunal interprets them afterward. Neither may rewrite the arbitration agreement or decide a matter reserved to a court by applicable law.
Rule 5 — Time and communications
Time runs in the procedural timezone in the locked seat overlay. If a period ends on a non-business day, it moves to the next business day unless mandatory law provides otherwise. Communications go through the case record and simultaneously to all parties. Email service is used only where the agreement, prior course of dealing, recipient or applicable law permits it. The Center may require cure or additional service; it records the method, recipient, time, delivery result and content hash.
II. Commencement and response
Rule 6 — Demand for Arbitration
A Demand must identify every party and representative; give addresses, email and phone; attach or quote the arbitration agreement; identify the contract, legal seat, governing law, agreement law and requested language; state material facts, claims, amount and other relief; identify known related proceedings; state the requested tribunal size and expedited treatment; disclose funding; attach core documents; and pay the filing fee. The claimant must simultaneously send the Demand to each respondent by an agreed or legally sufficient method.
Rule 7 — Commencement
The arbitration commences for administration when the Center receives a substantially complete Demand and required filing fee. This administrative date does not decide contractual or statutory limitation, tolling, service or jurisdiction. The Center issues a receipt identifying deficiencies, the locked rules version and the provisional classification.
Rule 8 — Registration review
The Center conducts a prima facie review of a written arbitration agreement naming Anrak or otherwise establishing consent to Anrak administration. It may request cure and may decline administration if no prima facie agreement exists, the category is excluded, a seat is unapproved, fees are unpaid, or administration would violate law or institutional integrity. The Tribunal retains authority under Rule 22.
Rule 9 — Notice and Answer
After registration, the Center sends the Notice and access instructions. The respondent has 14 calendar days from the recorded notice date to file an Answer stating admissions and denials, defenses, jurisdiction objections, counterclaims, relief, amount, tribunal preferences, related proceedings, funding and core documents. A counterclaim must identify its legal and factual basis and pay the applicable fee.
Rule 10 — No Answer
Failure to answer is treated as a denial and does not admit the claim. The arbitration proceeds, but no award may issue solely from default; the claimant must prove jurisdiction and entitlement, and the absent party must continue to receive material notices.
Rule 11 — Amendments
Before appointment, a party may amend with notice and any required fee unless the Center finds material prejudice. After appointment, amendment requires Tribunal permission considering delay, prejudice, jurisdiction and efficient resolution. A new party requires Rule 17.
Rule 12 — Representation
A party may appear through counsel or another representative permitted by applicable law. Changes must be promptly disclosed and may not be used to create a conflict or disrupt the proceeding.
III. Emergency, expedited and multi-party procedure
Rule 13 — Emergency relief
Before constitution, a party may apply for emergency relief with the application fee, requested order, verified urgency, notice to other parties, and disclosure of any ex parte court request. The Center appoints an independent emergency arbitrator ordinarily within one business day after a complete application. The emergency arbitrator promptly sets a fair schedule, may require security, and may grant only relief within the arbitration agreement and applicable law. The order may be modified by the Tribunal. Seeking judicial interim relief is not a waiver.
Rule 14 — Expedited procedure
The Center may apply expedited procedure where the aggregate claim and counterclaim do not exceed the published threshold, the parties agree, or exceptional urgency warrants it after consultation. A sole arbitrator, compressed exchange, limited discovery and a hearing of one day or documents-only process may be used. Any party request for an oral hearing is respected unless validly waived or the Tribunal determines otherwise under applicable law.
Rule 15 — Early disposition
The Tribunal may permit a dispositive application only after giving all parties an opportunity to comment and finding that it is likely to narrow or dispose of issues efficiently. The applicant must identify the legal standard and undisputed record. The Tribunal provides a fair response opportunity and a reasoned decision.
Rule 16 — Multiple contracts
Claims under multiple contracts may be filed together when the arbitration agreements are compatible and the disputes arise from the same transaction or series of related transactions. The Center makes a preliminary administrative determination; the Tribunal finally determines jurisdiction.
Rule 17 — Joinder
A party seeking joinder must file the request, basis for consent, claims against or by the additional party, and required fee before appointment unless the Tribunal permits later joinder. No person is joined without prima facie consent to the arbitration, a fair opportunity to be heard and consideration of prejudice and appointment rights.
Rule 18 — Consolidation and coordination reserved
Consolidation is not available under this version of the Rules. A future version may enable it only together with a published cross-case protocol covering notice to every affected party, submissions, neutral decision-maker appointment and disclosure, tribunal alignment, the consolidated record, fees, confidentiality, withdrawal, award form and enforcement. Separate arbitrations may be coordinated only by unanimous written agreement or other legally sufficient authority. This Rule does not authorize mass arbitration.
IV. Tribunal
Rule 19 — Number
The agreement controls. Otherwise one arbitrator is appointed. The Center may determine that three are appropriate after considering amount, complexity, public-law issues and party submissions, subject to the agreement and fee deposits.
Rule 20 — Appointment
The Center provides a legally screened shortlist with disclosures. In a sole-arbitrator case each party confidentially strikes and ranks candidates within 14 days; the Center appoints the highest mutually available candidate. For three arbitrators, each side nominates one from the screened roster and the two or the Center select the chair. The Center appoints if a party defaults, nominations create conflict or the method fails.
Rule 21 — Independence, impartiality and disclosure
Every candidate must be independent and impartial and disclose before appearing on a ballot any circumstance that might reasonably raise doubt, including relationships with parties, counsel, affiliates, witnesses, funders, subject matter and repeat appointments. The duty continues. The Center circulates disclosures and allows a 14-day challenge. The Center decides challenges before constitution; after constitution a neutral institutional decision-maker does so, never the challenged arbitrator alone.
Rule 22 — Jurisdiction
The Tribunal may rule on its own jurisdiction, including objections to existence, scope and validity of the arbitration agreement and whether claims are arbitrable, to the extent permitted by applicable law. The arbitration clause is separable. A plea must be raised no later than the Answer or response to the relevant new claim unless delay is justified. A Center registration decision is not binding on a court or Tribunal.
Rule 23 — Replacement and vacancy
An arbitrator who resigns, is removed, becomes unable to act or ceases to satisfy independence obligations is replaced under the original method. The reconstituted Tribunal decides, after hearing the parties, whether prior proceedings must be repeated.
Rule 24 — Tribunal secretary and delegation
A secretary may be appointed only after disclosure, party comment and written terms. A secretary performs organizational work and may not decide, deliberate as an arbitrator or replace independent Tribunal judgment. Compensation and data access must be disclosed.
V. Conduct of the arbitration
Rule 25 — Preliminary conference and procedural order
Promptly after constitution, the Tribunal holds a preliminary conference and issues Procedural Order No. 1 addressing issues, claims, governing law, seat, language, timetable, discovery, evidence, hearing format, confidentiality, cybersecurity, AI use, settlement, costs and award form.
Rule 26 — Equal treatment and opportunity to be heard
The Tribunal must treat parties equally and give each a reasonable opportunity to present its case. It conducts the proceeding proportionately, avoids unnecessary cost and delay, and records material rulings and service.
Rule 27 — Seat, venue and governing law
The selected approved seat and its mandatory law govern the arbitral procedure. Hearings and deliberations may occur elsewhere or online without changing the seat. The Tribunal applies the substantive law chosen by the parties; absent choice, it applies the law determined by applicable conflict rules. It may consider trade usages and contract terms.
Rule 28 — Information exchange
Exchange is limited to nonprivileged material relevant and material to claims or defenses and proportionate to the dispute. The Tribunal may order targeted custodians, date ranges, search terms, depositions, interrogatories or inspections; allocate cost; protect privilege and trade secrets; and draw appropriate inferences for noncompliance. Broad court-style discovery is not automatic.
Rule 29 — Evidence
The Tribunal determines admissibility, relevance, materiality and weight and is not bound by court evidence rules. Each party has a fair chance to test adverse evidence. Privilege is decided fairly, accounting for reasonable expectations and avoiding unequal treatment where laws conflict.
Rule 30 — Witnesses and experts
Witness statements may serve as direct testimony. A witness whose material statement is disputed must be available for questioning unless the Tribunal orders otherwise. Tribunal experts must disclose qualifications, instructions, materials and conflicts; parties may comment and question them.
Rule 31 — Hearings
Hearings are private. They may be in person, remote or hybrid after considering fairness, accessibility, security and party views. The Center records attendance, admissions and technical events. A transcript or recording is made only by agreement or order, with cost allocation and a protected authoritative copy.
Rule 32 — Interim measures and security
The Tribunal may preserve assets or evidence, maintain or restore the status quo, protect confidentiality, enjoin conduct within its authority, and order security for relief or costs where law permits. It states reasons and may modify relief. A party remains free to seek compatible judicial assistance.
Rule 33 — Defaults and noncompliance
If a party fails to appear or comply after proper notice, the Tribunal may proceed, impose proportionate procedural consequences, allocate costs or draw inferences. It must still test jurisdiction and the evidentiary basis for relief.
Rule 34 — Cybersecurity, privacy and AI
At the first conference the Tribunal adopts measures proportionate to data sensitivity, including access control, retention, breach response and transfer location. A participant must disclose material generative-AI use affecting evidence or adjudicative work when ordered or required by the AI protocol. Arbitrators may use AI only for assistive tasks consistent with confidentiality, due process and independent judgment; they may not delegate decision-making and must preserve required provenance.
Rule 35 — Settlement
The Tribunal may encourage settlement without coercion. On joint request it may record a lawful settlement as a consent award. A mediator may not become an arbitrator without informed written consent after the mediation.
Rule 36 — Closing the record
The Tribunal closes the record only after confirming that parties have completed authorized submissions and identifying any reserved issue. It may reopen for good cause before the award. The closing date starts the award period.
VI. Awards, costs and closure
Rule 37 — Award
The Tribunal issues a written, signed, dated, reasoned award identifying the seat, parties, agreement, procedure, jurisdiction, issues, findings, relief, interest and costs. A majority may decide a three-member case; a dissent may be attached without delaying delivery. The target is 30 days after record closing. Electronic signatures are permitted where legally effective. The Center reviews form, clerical completeness and enforceability flags without dictating merits.
Rule 38 — Remedies
The Tribunal may grant any remedy within the arbitration agreement and governing law, including declaratory, monetary, specific, injunctive, interest and cost relief. Punitive or exemplary damages require legal and contractual authority and express reasons.
Rule 39 — Correction and interpretation
Within 20 days after authenticated delivery, a party may request correction of clerical, typographical or computational error or interpretation of a specific dispositive passage. The other party has 10 days to comment. The Tribunal may correct on its own within 20 days. No request may relitigate merits. An additional award on an omitted presented claim may be requested within 20 days if law permits.
Rule 40 — Fees and costs
The published fee schedule is incorporated. The Center may require deposits and suspend or terminate administration for nonpayment after notice and an opportunity for another party to advance. The award states administrative fees, arbitrator compensation, expenses and allocation. Attorney fees may be awarded only by agreement or law. The Tribunal considers outcome, reasonableness and conduct.
Rule 41 — Delivery and post-award record
The Center delivers the authenticated signed award using the agreed and legally sufficient method and records actual transmission and receipt evidence. A portal opening alone does not create a legal receipt date unless the parties and applicable law make it so. The Center retains the institutional record under its retention policy and provides certified copies on request and fee.
Rule 42 — Court proceedings and finality
The award is final and binding subject to applicable law. Parties may seek confirmation, vacatur or modification within the periods and in the courts provided by the FAA, applicable seat law and their agreement. These Rules do not enlarge or waive statutory review. The Tribunal's mandate ends after permitted post-award action.
Rule 43 — Confidentiality and privacy
The Center, Tribunal and appointed institutional participants keep nonpublic case information confidential except for administration, enforcement, legal duty, safeguarding or anonymized statistics. Arbitration is private, but parties are not independently gagged unless they agreed or the Tribunal enters a lawful protective order. Awards are not published without consent or a legally required redacted publication regime.
Rule 44 — Waiver, severability and immunity
A known procedural objection must be raised promptly or may be waived to the extent law permits. An invalid rule is severed without invalidating the rest. The Center, arbitrators and institutional appointees are not necessary parties to enforcement proceedings and have immunity to the fullest extent permitted by law, excluding knowing misconduct that cannot lawfully be immunized.
Primary and benchmark sources for legal review
- Federal Arbitration Act, 9 U.S.C. chapters 1–4: https://uscode.house.gov/view.xhtml?edition=prelim&req=granuleid%3AUSC-prelim-title9
- New York CPLR Article 75: https://www.nysenate.gov/legislation/laws/CVP/A75
- Delaware Uniform Arbitration Act: https://delcode.delaware.gov/title10/c057/
- AAA Commercial Arbitration Rules (benchmark only): https://www.adr.org/rules-forms-and-fees/commercial/commercial-arbitration-rules-and-mediation-procedures/
- IBA Conflicts Guidelines 2024: https://www.ibanet.org/document?id=guidelines-on-conflicts-of-interest-in-international-arbitration-2024
- SVAMC AI Guidelines 2024: https://svamc.org/wp-content/uploads/SVAMC-AI-Guidelines-First-Edition.pdf