I. Introduction – II. Background – III. Implementation of Arbitration Conventions in a Federal System – III.I The Exclusive Spheres Model – III.II The Federal Preemption Model – III.III The Access Model – IV. Applying the Models to U.S. Implementation of the New York Convention – IV.I The Federal-State Clause of the New York Convention – IV.II To What Extent Does the Federal Arbitration Act Apply in State Court? – IV.III Is the New York Convention Self-Executing? – V. Party Autonomy and the Role of State Law Under the New York Convention – VI. Implications and Conclusions.