In Metal-Tech Ltd. v. Republic of Uzbekistan, an International Centre for Settlement of Investment Disputes (ICSID) panel unanimously dismissed an investment claim by an Israeli investor filed pursuant to the Israel-Uzbekistan Bilateral Investment Treaty (BIT) against Uzbekistan. The tribunal concluded that it lacked jurisdiction to hear the dispute because the investment was not “implemented,” i.e., “established” in accordance with the laws and regulations of Uzbekistan as it was the result of corrupt practices by the investor. To reach this conclusion, the tribunal relied, inter alia, on the requirement of consent as set forth in Article 46 of the ICSID Convention. Ultimately, the tribunal decided that as a consequence of having no jurisdiction over the claims, it had no jurisdiction over Uzbekistan’s counterclaims.

On September 30, 2014, Afghanistan signed agreements with the United States and NATO providing for U.S. and NATO military presences in Afghanistan following termination in December 2014 of the post-9/11 U.S. “Operation Enduring Freedom” (OEF) and NATO-led International Security Assistance Force (ISAF) military missions.

The United Nations (UN) Report on the Protection of Civilians in the Non International Armed Conflict in Iraq (Office of the High Commissioner for Human Rights and UN Assistance Mission for Iraq), UN Security Council Resolutions 2170 and 2178, and UN Human Rights Council Resolution S-22/1 (UN Documents) form a key part of the international community’s efforts to resolve, manage, and document the ongoing non-international armed conflict in Iraq.

On September 26, 2014, the Government of the Kingdom of Cambodia and the Government of Australia concluded a Memorandum of Understanding (MOU) Relating to the Settlement of Refugees in Cambodia. The agreement provides for refugees on the Pacific Island of Nauru to be voluntarily relocated to Cambodia. The Office of the United Nations High Commissioner for Refugees (UNHCR) and several international human rights organizations have lambasted the agreement, maintaining that Australia would be contravening its humanitarian and refugee obligations.