The beauty of mediation is that it is detached from any one legal system and it can be practiced by anyone, not only lawyers. Accordingly, being a French avocat or a New York attorney, or anything else, is irrelevant.
Mediation is akin to lex mercatoria , a domain that transcends jurisdictional boundaries.
Furthermore, mediation, also known as conciliation in many parts of the world, has long been used in diplomacy among foreign states. It is still the most prevalent dispute resolution technique in many parts of the world, like China and the Far-East generally, where litigation rather than mediation is considered the alternative dispute resolution technique. A learned French academic and arbitrator, Professor Charles Jarrosson, suggested that there is a nuance between mediation and conciliation, that mediation and conciliation are of the same nature but of different degrees, mediation being a more proactive form of conciliation, conciliation being more passive in the sense that in an conciliation, the conciliator has an evaluative role, whereas in mediation the mediator has a facilitative role. The author would not make such distinctions. Mediation is basically the same thing as conciliation, i.e., a non-binding procedure to resolve disputes.