On September 22, 2014, a Tribunal at the International Centre for Settlement of Investment Disputes (ICSID Tribunal) upheld [3] an award for US $42 million in favor of US-based El Paso Energy International Company against Argentina regarding the state’s actions in response to its 2001 financial crisis.  The decision notes that the Tribunal in the original arbitration “concluded that Argentina had breached its obligation to accord fair and equitable treatment to El Paso’s investment, under the BIT [4] [Treaty between the Argentine Republic and the United States of America concerning Reciprocal Encouragement and Protection of Investments].”  Regarding Argentina’s request for annulment of that award, the ICSID Tribunal stated “there was no violation of due process or the right of defense, as fundamental rules of procedure. Argentina had the opportunity to defend itself and to express its point of view on the effect of the measures that it adopted during the crisis, and on the general legal framework” and decided that the request was “dismissed in its entirety.”