844 (6th Cir.1996). In that case, we held that a party seeking to vacate an arbitral award was limited to raising the exclusive grounds found in Article V of the Convention because the FAA does not apply to cases under the Convention if the FAA is “in conflict” with the Convention or its implementing legislation. Id. at 851; see also 9 U.S.C. 208. Unlike the award in M & C Corp., which had been made in the United Kingdom, see id. at 846, the award in this case was made in the United States, and therefore Article V(l)(e) authorizes this court to consider our domestic law, as it is the law where the award was made. Therefore, the FAA and the Convention do not conflict in this case. 9 . An arbitration award can fall under both the Convention and the FAA. See Lander Co., 107 F.3d at 481 (<HOLDING>); Bergesen, 710 F.2d at 934 (“There is no
holding that both faa and taa applied where contracts stated they shall be governed by the law of the place where the project is located holding that where an ambiguity exists in fact or by construction it is proper to consider the history of the legislation holding that the term commerce in the faa is to be broadly construed holding that a dispute is governed by both the convention and the faa because nothing in the convention or its history or in the implementing legislation or its history suggests exclusivity from the faa  holding a court may consider a defendants criminal history even if that history is included in the defendants criminal history category