Jurisdiction - China
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Asia Pacific – Investment Arbitration in Asia: The Way Forward For Asia On The Rise.
10 October , 2014

Legal News & Analysis – Asia Pacific


It is 2007 and just like many other countries in Asia, The Lao People’s Democratic Republic (“Lao PDR”) was in the midst of experiencing economic growth and on track to becoming a member of the World Trade Organization, finally having been admitted in 2013 after applying 15 years earlier.  At the time it was admittedly a “land-locked, least developed country”  that had been in the course of implementing comprehensive reform programs since the mid-1980’s with a view to transforming the economy from a centrally planned one to a market oriented system, according to the opening statement to the WTO by then Lao PDR Commerce Minister Soulivong Daravong.  As underdeveloped countries see growth and start to realize their economic potential, they begin to take steps to promote free-trade and encourage foreign investments.



This was just the case when in late 2007, a group of local investors from Lao PDR doing business as the ST Group met with Sanum Investments Limited (“Sanum”), a company established in Macau Special Administrative Region of the People’s Republic of China,with regards to the financing of a resort and gaming project in Lao PDR.  During the course of negotiations, the company met with not only ST Group, but also with then Prime Minister Bouansone Bouphavanh, who later resigned from office in December 2011, officials from his office, and other high ranking Loa PDR officials.


One of the biggest concerns for any foreign investor is the security of their investment especially with third world countries.  Sanum was no different, and according to their Request for Arbitration, among the many assurances that they relied upon in making their decision included representations made by Prime Minister Bouphavanh and other Lao PDR officials.  They alleged to have been told that the country had entered a new era and helda strong respect for the rule of law and rules of investment.  Moreover, as evidence of the country’s commitment to protection of foreign investors it was pointed out to Sanum that Lao PDR was on track to becoming a WTO member and they were signatories to a number of bilateral investment treaties (BITs).  In addition, Sanum alleged that the Prime Minister himself personally vouched for ST Group calling them an “honourable business.”  Having further believed they were promised a favorable and certain tax regime for its business ventures, ongoing support by the government, and certain gaming monopoly rights, Sanum agreed to this business endeavor.[1]


Of the BITs, the Agreement Concerning the Encouragement and Reciprocal Protection of Investment between theGovernment of the People’s Republic of China and the Government of Lao PDRis of note since it was applicable in this case.  It mandates a six month attempt at negotiations to resolve disputes, thereafter an option to litigate within the appropriate courtor if the dispute concerns compensation for expropriation they may apply to an ad hoc arbitral tribunal.


The result of the negotiations was a master agreement, two project development agreements, and a participation agreement for three different joint ventures including two casinos and five slot clubs.  The project development agreements provided for arbitration in the Economic Dispute Organization in Singapore.  With respect to the two casino projects, Sanum was to be the controlling shareholder owning 60%, Lao PDR 20%, and the local investors 20%.  Sanumcontended that they then began investing over $85M USD in the development of these projects.  Sometime thereafter, things went afoul with all three joint ventures due in part to the cancellation of certain gaming licenses, closure by the government of one the enterprises, and expropriation of the monopoly gaming rights that were allegedly granted to Sanum.  Moreover, there were claims of special ties between the Lao PDR government and ST Group that Sanum was unaware of.  For example, the daughter of the President of ST Group was married to the son of Bounnhang Vorachith, who was Prime Minister from 2001-2006 and subsequently the Vice President of the Republic.[2]


The parties attempted to negotiate for at least six months per the Treaty and then Sanum sought relief by way of investment arbitration against Lao PDR.  Years later and emptier pockets to boot, the parties finally settled in 2014.


Had arbitration not been available and no BIT in place, perhaps Sanum would not have endeavored upon this risky venture.  However, risky ventures can turn large profits especially when investing in countries with large populations and fast growing economies with attractivereturn on investment projections.   These types of investments are vital for many underdeveloped countries with an eye to continued growth andmore competitive participation in regional and global free trade.


The concern that often arises is that less sophisticated and underdeveloped nations may not be able to offer favorable legal methods for seeking redress in the event of a breach of contract, expropriation of rights, nationalization or privatization.  Further, states may find it difficult to provide reliable and certainjudicial procedure or even assure you that bias for the host country does not exist within the courts.  Take for example, the expropriation of the petroleum industry by Mexico in 1938, the re-nationalization of the space industry by Russia in 2013, and the privatization of the power industry following the 2001 Philippines power crisis.  While states and state owned enterprises encourage foreign investment they sometimes lack the tools to secure it in light of the apparent risks investors may face.


In Asia, a region many savvy investors consider to be the land of promise due in part to the number of emerging markets, population size, rise in those being college educated, and a growing middle class with money to spend, there is a great degree of legal uncertainty and economic insecurity to consider.  However, investor-state arbitration can offer procedural legal certainty and an unbiased forum for investors to seek redress against a state or state owned enterprise.  Hence, the increasing inclusion of investor state dispute resolution options found in the many BITs, free trade agreements such as NAFTA and CAFTA, and international investment treaties such as the Energy Charter Treaty.  This is one of the many captivating topics that will be addressed at HKIAC’s 3rd AnnualArbitration Week to be held in Hong Kong this October 2014.


I. Investor-State Arbitration: A Deal Maker


Investor-state arbitration is a mechanism of international law that allows a foreign investor the right to initiate arbitration proceedings against a foreign government or a state owned enterprise.  It is one the many avenues for alternative dispute resolution, and it can offer a certain degree of legal security for those desiring to make a foreign investment.


Host states can make investment arbitration as a part of their sales pitch, and foreign investors can also demand that it be a condition of the contract.  The lack of international alternative dispute resolution options can be a deal breaker while the offer of one can be a deal maker.


“Indeed, I view investment state arbitration as just an extension of the basic original and continuing purpose of international arbitration.   This method of dispute resolution — which actually is a 20th century phenomena and came into being and popularity as cross border commercial transactions grew in activity and promise — has been a hero in promoting globalization of commerce by giving parties greater security and confidence in the dispute resolution opportunities through international arbitration versus international litigation with its vagaries,” opined Selvyn Seidel, founder and current CEO of Fullbrook Capital Management, an entity in the third party funding industry which emphasizes international arbitrations, and former Senior Partner at Latham & Watkins LLP, where among other positions, he founded and chaired the international litigation and arbitration group.


For countries within the Asia-Pacific regionthat are on the rise, international trade and investment are undoubtedly necessary for their future prosperity.  However, the task can be daunting for a foreign government when its legal system cannot offer substantive or procedural legal security in the event an investor has a claim against the state….in comes investment arbitration as a handy tool for securing state contracts with foreign business.


Take for example China, who is now renegotiating some of it BITs in an effort to not only attract more inbound investments but also to make their own investors more attractive to foreign countries.  China has approximately 88 companies in the global Fortune 500 up from 8 in 2003 much due to both inbound and outbound foreign growth.Furthermore, China’s GDP has averaged approximately 10% per year since the late 1970’s.  As evidence of China’s appetite for investing abroad all one has to do is look at the fact Chinese companies now own old world vineyards in France, western food companies such as Smithfield Foods, and European classics such as Volvo.[3]  Thus, there is a great deal of incentive for China to create a more investor-friendly climate for foreign businesses as well as develop a level of trust and rapport with foreign states so that more doors are open for its citizens to invest in global markets.


However, even with BITs in place governments want more assurances for their citizens who want to do business in China and other developing states.  Of concern to the U.S., for example, who just completed its 6th round of Strategic and Economic Dialogue negotiations with China with promising results for an agreed upon BIT sometime in the near future, is the potential for legal practices by China that may result in discrimination against foreign businesses to protect domestic competitors.[4]  There is also a fear of litigating in China’s domestic courts since its judicial system is intricate and at times has delivered surprising and audacious judgments.  Having the ability to arbitrate instead of having to apply to China’s local courts or for that matter any other emerging nation’sdomestic court, greatly enhances one’s sense of investment security.  China and the U.S. along with 150 other sovereigns are signatories to the New York Convention, and thus will recognize foreign arbitral awards from their respective jurisdictions, but the right to arbitrate against a state in the event there is a grievance is not absolute unless it is provided for in the investor’s contract or a treaty or trade agreement of some sort.


II. The Good And The Bad


While investor-state arbitration is an attractive incentive, it does come with considered pros and cons.




There are many advantages that investment arbitration can offer over traditional litigation including a neutral forum and legal security, confidentiality, the ease and reach of enforcing arbitral awards, finality, the level of adeptness international arbitrators can provide and autonomy and flexibility.

One of the top advantages is “the ability to have one’s case heard before a neutral forum that is fully independent from the host state,” said Mark Bravin, Partner and Global Co-Chair of the International Arbitration Practice at Winston & Strawn LLP.  He went on to say that “before BITs it was difficult to arbitrate and secure a neutral forum unless it was provided for in the investor’s contract.  Now investors can enter into higher risks countries with some assurances that if the host state fails to protect their investment as required by the BIT they will have a neutral forum to seek compensation.”


A neutral forum, one that is not subject to the influence of the domestic judiciary or executive can be a very important safeguard in a host country where there are local, political, economic or social issues.  According to Phillip Rompotis, former barrister and now Partner and arbitration specialist at Stephenson Harwood, “A neutral forum offers a level of protection for both the investor and the state which is beneficial to both.  Having made a substantial financial commitment, the investor derives some comfort knowing that if a dispute arises, it will be resolved in a neutral forum, immune from domestic influence, whether in the form of political pressure or lack of judicial independence.  On the flip side, the host nation is better able to attract significant foreign investment by offering a neutral forum to resolve disputes.”


An additional important advantage with investor-state arbitration is the enforceability of the award.  “Generally international arbitration awards are easier to enforce than national court judgments,” Bravin noted.  “Treaty arbitration awards issued by ICSID are enforceable in about 160 countries that signed the ICSID Convention, and most other treaty arbitration awards are enforceable in about 150 countries that have ratified the New York Convention.  By contrast, national court judgments will be enforceable in the courts of another nation under its domestic law which generally gives the enforcing courts wider latitude in deciding whether to enforce,” Bravin further stated.


A related key bonus as noted by Kam Nijar, Asia Pacific Counsel for Skadden, is that “arbitration awards are final and binding.  With domestic court litigation there may be a right to appeal.  Delays such as this could cost the parties a lot more money and time.  Arbitration can offer finality, which is important.”


In addition to the above noted plusses, another very important benefit is the idea parties will be in the hands of those who have a greater understanding of international law, applicable treaties, guiding principles of global investment rules, and of investment arbitration rules and process.  As Bravin explained, “Unlike national court judges, who are not likely to be familiar with these international legal doctrines and procedures, most arbitrators appointed to decide treaty claims have gained the necessary specialized knowledge and experience in previous arbitrations, either as arbitrator or as counsel, and many also have researched and taught relevant subjects at well-regarded law schools.”


As another benefit enjoyed by arbitration, parties like the level of autonomy and flexibility it offers when compared to domestic court litigation.  According to Nijar, “The parties will have a say in choosing the venue, arbitration institution and/or rules, and the tribunal.  When selecting the tribunal, you can choose arbitrators that are experts in the subject matter of the arbitration and the relevant area of law.”  Having a panel that has such an understanding is especially beneficial if the case is particularly technical or complex.”




While there are many advantages to investment arbitration, it also has some reasons for pause.  Arbitration procedures at times can be long, complex, and quite costly.


There are a number of factors that can contribute to lengthy proceedings such the nature of the dispute, dispute amount, and the number of involved parties.  Rompotis notes that, “International arbitration proceedings often take on a life of their own, with multiple proceedings in various jurisdictions being common, particularly at the enforcement stage.  A feature of some of the BITs and international treaties is that they allow, in certain circumstances, the involvement of third parties, particularly where disputes contain a social, wider economic or environmental element.  This ability for a non-party to join an arbitration, a virtually unknown concept in private arbitrations, can delay the resolution process considerably and add to the costs and uncertainty.”


As a cause and effect, length and complexity often lead to higher cost claims.  “Investment arbitration is known for its being, all too often, protracted in time and very expensive,” noted Seidel.   On average 90% of costs are incurred by the parties according to statistics produced at a conference by the International Federation of Commercial Arbitration Institutions, while only 3-5% actually go to the arbitral tribunal & arbitrators.[5]In commentary made at the International Dispute Resolution Involving Russian and CIS Companies Convention in February 2014 by Professor Emeritus Karl-Heinz Bockstiegel, he noted thathe has seen costs as high as $50M USD per side.[6]


When comparing the cost of investment arbitration to litigation, in some instances there does not seem to be much difference. Up until a certain point, the reasonablecost to arbitrate was among its many selling features.  According to Seidel, “Lower costs were, early on and still today, advertised as a big benefit of arbitration.  Today, however, many experts like to say that the complex arbitrations are all too often approaching the range of costs and time consumption of complex litigations. In fact, the parties have the extra costs of having to pay for the arbitrators and the administration of the arbitration.   The cost gap and advantages on this score of international arbitration over international litigation has certainly and sadly dwindled.”  Rompotis adds that, “These days, there is, in reality, very little difference in the way in which many practitioners run litigation and arbitration matters.  The distinction has certainly blurred, and the advantages of arbitration over litigation are probably best found elsewhere than in the savings in costs.”

A number of factorscan lead to high cost claims including the size of the legal team representing each side, court reporters, expert witnesses, interpreters, and copy costs to name a few.Nijar adds, “Factors that can make costs unpredictable include the other party’s case strategy and any interim applications that your client may face or have to make.”


However, while costs may seem excessive, the time and costs involved in resolving a foreign investment dispute should be seen in relative rather than in absolute terms.  At least this is the perspective Rompotis takes.  “My experience suggests that the time and costs involved in resolving a foreign investment dispute is but one of many important factors for the parties involved. The reality is that foreign investment often involves a substantial financial commitment by a party, particularly, for example, where the construction of large scale infrastructure is concerned.  The costs to resolve a dispute must be seen in the context of such a financial commitment.  Further, where a foreign investment involves the investor in a long term contractual commitment, such as often in build operate and maintain contracts or a long term concession agreement as is common in the energy sector, the return on investment is often measured in the billions.  The time and cost to resolve any initial dispute is often not as important a factor as obtaining certainty as to obligations and risk.”


With that said, there are cases in which a party does not have the money or runs out of fundsmidway thru either pursing or defending a claim. Thus, costs can have very real and negative consequences for those who cannot afford it.  Nonetheless, for some there are avenues to address this problem when it arises such as assistance by third party funders.  “The greater potential, reliability, objectivity and predictability of international arbitration — among private parties and against a sovereign under investment treaty arbitration — has also encouraged third party funders to step in and help the claimant with a good claim by paying for the prosecution costs and other costs in return for a benefit if the claim is successful that is often linked in some way to the recovery,” said Seidel.


On balance, the value of the benefits is substantial as opposed to the drawbacks.  It is undeniable that Asia is full of investment opportunities with the number of emerging markets and China being its frontrunner.   As Nijar puts it, “Arbitration is not a perfect system, but with BIT and/or ICSID rights, combined with a well drafted concession agreement, investment arbitration can be an effective means of mitigating some of the risk of investing.”


III. To Be Or Not To Be: Transparency Or Confidentiality?


In addition to investment arbitration in Asia being a key topic, another hotly debated issueis with the level of transparency investor-state arbitration proceedings should come with.

Published opinions that detail a judge’s reasoning for rendering a particular interim decision or final judgment is necessary in a system that follows precedents such as the common law system which adheres to the doctrine of stare decisis.  In this respect, transparent proceedings and judgments are pertinent.  However, in a system that renders decisions without reference to stare decisis and has primarily operated in and benefitted from secrecy,the concept of transparency is somewhat new and continues to evolve in international arbitration.  According to Bravin, “Parties in investor-state arbitration have to agree to publication of the arbitral award, which they increasingly do, but the pleadings submitted during the dispute and what happens in hearings seldom are made public.  Inclusion of transparency rules, as was done in the 2013 United Nations Commission on International Trade Law (UNCITRAL), eventually may lead to greater openness.  That is the aim of special interest groups and non-profitslobbying for greater access to a process in which the final outcome can affect the interests of many who are not parties to the arbitration.  I think that change may take longer in Asia, though, where the confidential nature of international arbitration is aligned with broader cultural values and will continue to be viewed as extremely important to the involved parties.”


In discussing this topic, Seidel stated, “In general and according to specific design, a fundamental benefit of international arbitration is confidentiality.  That of course carries its own baggage of problems, but as a rule, was and still is considered a major benefit.  Investment arbitration breaks away somewhat from this doctrine, and for many reasons, such as the fact that a Sovereign is involved, more information thus should be available, people have said.”


Perhaps as arbitration rules are further developed and treaties are written anew or renegotiated, there should be delineated exceptions to when transparent proceedings are required, or rather parties should have to qualify their need for confidentiality.  Creating such a list may be a challenging task, but the reality is the public is largely the beneficiary of business ventures between sovereigns and investors, and thus arguablythey have a vested interest in the outcome of disputes that arise from it.  According to Rompotis, “Investor-state arbitration is a different animal to purely private commercial contracts because the public purse and public interest is often involved.  Arguably, the public has a right to know if, for example, the construction of an oil rig results in environmental damage to local fisheries and livelihoods, or where allegations of corruption or bribery are concerned.”


Bravin opined, “Depending on the nature of the dispute, the need for transparency may be more evident quite apart from concerns of that kind. Take for example the investor-state disputes in Europe over green energy, wind, and solar power policy, those tend to engender a great deal of public interest.  Whereas the breach of foreign investor’s contract to build a road might not generate as much public interest.  Another example is mass claims which involves a large number of claimants, such as the tens of thousands of Italian bond holders with claims against Argentina, where it had been argued that arbitral proceedings should be highly transparent and also allow for amicus briefs.”  In that case over 50,000 Italian bondholders are pursuingICSID proceedings against Argentina after it allegedly targeted them to invest in Argentinian bonds, and then subsequently defaulted on the sovereign debt.


“The greater the public interest, the stronger the argument for transparency.  The amount of transparency that may be called for should be viewed on a case by case basis,” Bravin added.


The Pros Of Transparency


While confidentiality is viewed as a perk by many, there are strong arguments in favor of transparency with investor-state arbitration.  Transparency can be shaped so that only the award with the arbitrator’s rationale is made public or it can require some or all documents submitted to the tribunal be made public.  It can provide consistency and can help create a bank of shared information on interpretation of laws and treaties which may prove helpful to future arbitrations even if precedent is not followed.


Rompotis is an example of someone who sees high value in transparency.  “There are many that would disagree with me, but I believe that arbitration as a form of dispute resolution could be strengthened if we had more transparency, particularly where an arbitration award deals with a commonly recurring legal issue, such as the interpretation of a term in a standard form contract as is prevalent in the construction industry.”


Another important consideration is that arbitral opinions made public may help arbitrators in future cases save the parties valuable time and considerable costs and be confident in their decisions if there was a bank of shared information on interpretation of laws.  Rompotis believes that such an approach could be of benefit to the lawyers involved, “I have advised on two different disputes, 15 years apart, involving virtually the same point of law.  Had the decision in the earlier case been available publicly, we may have been able to avoid a lot of time, and the client a lot of money resolving the later dispute.”


“In court proceedings, there are some jurisdictions in Australia where the chief justice authorises the release of a short summary of the case containing a brief summary of the facts, the key legal issues arising in the dispute, the decision and any relevant or interesting pointers for the profession; with appropriate modification, such an approach with arbitration awards many be helpful,” reflected Rompotis.


The Cons Of Transparency


Just as there are arguments for transparency, there are also some grounded arguments against it.  Confidential proceedings can allow for more flexibility and help the losing party better manage the effects of the outcome with its constituents, stockholders, or consumers.



A benefit of arbitration that is done in confidentiality is that it allows for greater flexibility with the process.  Whereas less flexibility comes with transparent proceedings.


Bravin offered another view when he reasoned that, “It’s not less flexibility in what they can do but rather less flexibility in what they are willing to do.  For instance, arbitrating parties may be less cooperative in responding to legitimate requests for document disclosure if they know that the documents exchanged by the parties are open to the public.  Greater transparency, even when done by agreement, may affect a party’s willingness to disclose full facts.” He did, however, note, “There are ways to deal with that, for example, if a company has proprietary information, it can explain the need to redact confidential details that would be part of the public version of its pleadings and the final arbitral award.  States may have similar interests.”


“If an arbitration is conducted in front of an open audience, inevitably the parties will be mindful of how they will come across to the public and the media, rather than concentrating solely on presenting their case.  Even an arbitrator may bear the audience in mind when conducting the proceedings, for example, providing more detailed explanations for the benefit of the public where none may otherwise have been required.  In both cases elongating the process and perhaps increasing the costs,” Nijar observes.


Outcome Management


Since investor-state arbitration deals with claims against or by a state, the contracts may involve a country’s natural resources, infrastructure, or other public interests.Thus, there is a certain audience cost among its constituents for a host state if they are not the prevailing party.

States may find themselves walking a fine line between appeasing its constituents and making nice with an investor if the investment itself is a long term one that a government deems beneficial and needed such as with energy, solar, and mining contracts. The fact is if a state is being sued in arbitration by a well-known company, at the very least the public will learn of the arbitration.  However, it is more difficult to navigate thru the muddy waters of bad publicity if all the proceedings are made public especially if the public does not feel it would be right or in the country’s best interest to capitulate to an investor by agreeing to generous settlement terms.[7]  Thus, one arguable disadvantage with more transparency is the loss of this benefit.


The same rings true for a company as among its stockholders or consumers, if it is unsuccessful.If the proceedings are done privately and the settlement award is not made public, the losing party can better manage the outcome and perhaps avoid a fallout.


In looking at arguments that are for and against transparency, at the end of the day most feel that there is no question that arbitrators are trying to do the right thing whether or not the proceedings are shrouded in secrecy or made open to the public.  They may adjust their methods and more cautiously choose their words, but they will always respect the process as well as the institutions and parties they serve.  However, some are of the opinion that would it not just be easier on the arbitrators and the parties involved by making arbitration a bit more transparent.  As Rompotis so aptly put it, “why fumble around in the dark, when you can simply flick on the light.”


IV. Peering Into The Crystal Ball: The Future Of Investment Arbitration In Asia


In looking ahead at the role investment arbitration will play in Asia’s future, many are forecasting a rise in the number of these type of cases as more emerging markets open their doors to investment and BITs continue to be written anew to includeit as an option for dispute resolution.  It will undoubtedly continue to help secure much needed inbound investments which in turn will help many Asian countries become more competitive globally.


Per Rompotis, “Asia continues to be ripe for investment.  With developing markets and an emerging middle class, there are many opportunities for foreign companies to invest and prosper in Asia.  There continues to be a need for a mechanism to resolve disputes when they arise other than within the local courts.”


“International investment is fundamental to the future prosperity of Asia.  It’s really a question of economics.  In developing countries the need for growth is fundamental.  There are a lot of projects that need financing and that requires inward investment.  For example, developing countries need infrastructure and such projects have large capital outlay and require foreign expertise.  As more business is done with Asian countries in terms of both inward and outward investment- China being a prime example of both- we can expect to see an increase in disputes and the use ofinvestment arbitration,” reasoned Nijar.


In fact, Seidel is of the opinion that, “While it has had bumps along the way, including countries withdrawing, it will survive them and it will become more and more used.  Arbitration exists and is flourishing in Hong Kong and Singapore and elsewhere.  This, coupled with the fact that emerging Asian countries need capital and foreign investments, will be responsible for growth.  The international expansion of commerce includes Asia of course, and it will increase. Factors like these are a recipe for growth and a bright future for investment arbitration in Asia.”

Just as Loa PDR was able to utilize the attractiveness of opportunity within their borders and legal security by way of offering investment arbitration as a means of resolving disputes to sell the dream to Sanum, so too can other Asian countries to potential and worthy investors.


[1] Sanum Investments Limited v. Lao People’s Democratic Republic UNCITRAL, PCA Case No. 2013-3, Notice of Arbitration August 14, 2012

[2]Sanum Investments Limited v. Lao People’s Democratic Republic UNCITRAL, PCA Case No. 2013-3, Award on Jurisdiction December 13, 2013

[3] Time, Red Red Wine, Lisa Abend, Oct. 6, 2014, pgs. 30-35

[4] China-US Focus, A High Standard Bilateral Investment Treaty, He Weiwen, http://www.chinausfocus.com/finance-economy/a-high-standard-bilateral-investment-treaty/

[5]Professor Karl-Heinz Bockstiegel, Practical Issues and Perspectives of Investment Arbitration Involving Russian and CIS Parties, Conference for International Dispute Resolution Involving Russian and CIS Companies, February 27/28, 2014

[6] Professor Karl-Heinz Bockstiegel, Practical Issues and Perspectives of Investment Arbitration Involving Russian and CIS Parties, Conference for International Dispute Resolution Involving Russian and CIS Companies, February 27/28, 2014

[7]Transparency of Investor-State Arbitration, Emilie M. Hafner-Burton, Zachary C. Steinert-Threlkeld, and David G. Victor, September 13, 2013


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For further information, please contact:


Tara Shah, Reporter, Conventus Law

[email protected]

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