Interestingly, the Advocate General ranged much more broadly in reaching the same conclusion, stating that these
limitations on the review of international arbitral awards were «contrary to the principle of effectiveness of EU law», «(n) o system can accept infringements of its most fundamental rules making up its public policy, irrespective of whether or not those infringements are flagrant or
obvious» and «one or more parties to agreements which might be regarded as anticompetitive can not
put these agreements beyond the reach of review under Articles 101 TFEU and 102 TFEU by resorting to arbitration» (AG Op § § 58, 67 and 72).