Introduction

On 2 August 2006, an ICSID tribunal dismissed for lack of jurisdiction all claims brought against the Republic of El Salvador by the Spanish company Inceysa Vallisoletana S.L. ("Inceysa"), in a ruling believed to be the first ever to rest on interpretation of "accordance with law" clauses found in many bilateral investment treaties. The award may stand as a stark warning to the unscrupulous who would prey on small countries and bolster the reputation of ICSID as a forum for even-handed resolution of investment disputes.