In Industrial Risk Insurers v. M.A.N. Gutehoffnungshutte GmbH, 141 F.3d 1435 (11th Cir. 1998), the Eleventh Circuit had held that Article V, rather than the FAA, governed the grounds for vacatur of an award in an arbitration governed by the Convention held within the United States. Did BG Group plc v. Republic of Argentina, 572 U.S. 25 (2014), changes that conclusion. In BG, the Court considered and rejected an argument for vacatur under § 10 in such a case. Was it making a holding, sub silentio, about the applicability of § 10? No, today's case says, because in Inversiones y Procesadora Tropical INPROTSA, SA v. Del Monte Int'l GmbH, 921 F.3d 1291 (11th Cir.), cert. denied, 140 S. Ct. 124 (2019), held that BG had not overruled Industrial Risk.