After thinking about this for awhile, for polygons that contain arcs I think there are three ways to do this.
One, is to break the arcs into line segments and then use the area formula as described above. The success of this approach seems to be tied to how close the interpolation of the arcs is as this could cause the polygon to intersect itself.
A quicker way than the above would be to do the interpolation of the arcs and then find a vertex in the corner (minimal Y, if tie minimal X) and use the sign of the cross product for that vertex. Positive CCW, negative CW. Again, this is still tied to the accuracy of the interpolation.
I think a better approach would be to find the midpoint of the arc and create two line segments, one from the beginning of the arc to the midpoint and another from the midpoint to the end of the arc and replace the arc with these line segments. Now you have a polygon with only line segments. Then you can add up all the normalized cross products of all the vertices. The sign will tell you the direction. Positive is counter-clockwise, negative is clockwise. In this case it doesn't matter if the polygon self-intersects.