The answer will depend on the parties’ arbitration agreement or the rules of the organization designated to administer the arbitration or appoint the arbitrators.  For example, under the Rules of the International Centre for Dispute Resolution (ICDR), which is the international branch of the American Arbitration Association, the parties may request that the ICDR appoint a neutral arbitrator who is not a national of the countries of any of the parties, and the ICDR also may do so on its own initiative.  The AAA/ICDR frequently calls upon established arbitration organizations of other countries to supplement its list of "foreign" arbitrators.  Other organizations within the United States feature international panels of arbitrators from within the United States and from outside the United States.  For example, the International Institute of Conflict Prevention and Resolution (CPR) Cross-Border Disputes Panel is composed of neutrals located in North America, and the CPR Global Panel includes neutrals located worldwide, outside of North America.   JAMS International maintains an arbitration panel with arbitrators from the United States and most countries in Europe.