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Investor Presentaiton

16 INVESTOR-STATE DISPUTE SETTLEMENT: A SEQUEL (and more traditional) approach, exemplified by most bilateral investment treaties (BITS) concluded by European countries. It allows for a broad range of ISDS claims and contains few procedural specifications, leaving virtually all procedural aspects to be determined by the selected rules of arbitration or by the arbitrators, in exercise of their discretion. The second, more recent, approach features a more circumscribed scope for ISDS claims and more detailed procedural rules with a view to setting out clear conditions of investors' access to ISDS and in the interests of a more effective, predictable, legitimate and cost-effective process. Under this approach, a number of new elements are addressed by the treaty itself, as opposed to being left to "outside" arbitration rules or to interpretation by the arbitral tribunal. States can choose how to combine specific elements in order to craft an ISDS regime tailored to their interests. Some elements are indispensable to the crafting of an operational ISDS provision (consent to arbitration, scope of the ISDS clause, available arbitration forums). Other issues are complementary and will depend on the specific policies and concerns of the States negotiating the IIA. Some States may choose to limit investor access to ISDS with a view to slowing down the proliferation of ISDS proceedings, reducing the risk of States' significant financial liabilities and saving resources. A far-reaching version of this approach would be to abandon ISDS as a means of dispute resolution altogether, as some countries have done. Other States may be content with the status quo. Section 6 of UNCTAD's Investment Policy Framework for Sustainable Development (IPFSD), as well as section III of UNCTAD Series on International Investment Agreements II
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