A v B, 5A_427-2011
Facts:
A.
A.a On 17 February 2001, the Syrian company, B.________, formerly known as C.________, and the Slovak company, A.________, entered into a contract for the delivery by the latter to the former of 7,350 cold-rolled laminated bands (aluminium) from Kazakhstan, amounting to US$ 2,285,850. On 20 May 2001, the Commercial Bank of Syria (hereafter: CBS), located in Damascus (Syrian Arab Republic), issued documentary letter of credit no. xxxx as a guarantee of payment of the agreed price, payable upon presentation of certain documents. On 4 October 2001, acting as confirming bank, the Union of Arab and French Banks SA (hereafter: UBAF) located in Neuilly (France), accepted the documents submitted by A.________ and paid US$ 2,264,992.87 into the latter's account with D.________ SA in Geneva.
Subsequently, C.________/B.________ had doubts as to the authenticity of the documents communicated by A.________ and alleged that it had not received the goods upon which they had agreed. In December 2001, it filed a request for arbitration before the Syrian Council of State in order for it to rule on the dispute between it and A.________. It relied on a pro forma invoice dated 22 February 2001, Art. 7 of which appointed the aforementioned authority to carry out the arbitration and stated that any dispute would be governed by Syrian law (“Arbitration: According to Syrian law and befor [sic] the Council of State in Damascus”). According to this arbitration, A.________ employed fraudulent means to obtain payment of the documentary credit letter by using a falsified inspection certificate and bill of lading. A.________ refused to proceed before Syrian authorities, alleging that the parties had modified their agreement and had agreed to have any dispute arbitrated by the Slovak Chamber of Commerce and Industry.