It would depend on the arbitration rules under which the investor chose to bring the claim. Most treaties give investors a choice of rules. If the investor brought the claim under the ICSID rules, there's an opportunity for so-called annulment proceedings, which are quite light touch and which are decided not by a court but by another panel of arbitrators. The members of that panel would be appointed under the authority of the World Bank president. So there's a light touch review option, but it's outside of any court process under the ICSID rules.
If the claim is brought under other sets of rules, especially the UNCITRAL rules or what are called the ICSID additional facility rules, and this is typical for arbitrations involving Canada.... Canada has been s been sued about 35 times under NAFTA, and those are usually under the UNCITRAL rules and the ICSID additional facility rules. The way it works is that the arbitrators choose which domestic courts will have the authority to review the arbitrators' decisions. So it could be a foreign court, it could be a domestic court, but again, typically it's a very light touch review. There's not rigorous and extensive judicial review of the ad hoc arbitrators' awards.