The law of the arbitration agreement governs the arbitration agreement and will apply for issues such as validity, formation, and interpretation of the arbitration agreement. This law of the arbitration is usually not expressly mentioned in the contract. This practical reality was acknowledged by the Supreme Court of the United Kingdom in Enka Insaat Ve Sanayi AS v OOO Insurance Company Chubb [2020] UKSC 38 (" Enka v Chubb ") – " it is rare for the law governing an arbitration clause to be specifically identified (either in the arbitration clause itself or elsewhere in the contract)".