Following the position that the UKSC itself set out just last year in the case of Enka v Chubb [2020] UKSC 38, the UKSC unanimously held that although there was no express choice of governing law for the arbitration agreement, the parties had included an express choice of English law to govern the underlying FDA and that this should therefore be extended to apply to the arbitration agreement: "the effect of (the governing law clause) is absolutely clear. Clause 15 of the FDA is a typical governing law clause, which provides that "this Agreement" shall be governed by the laws of England. Even without any express definition, that phrase is ordinarily and reasonably understood (for the reasons given at paras 43 and 53 of our judgement in Enka) to denote all the clauses incorporated in the contractual document, including therefore (the arbitration agreement clause)" (paragraph 39).