Summary

Petitioner ICS Inspection and Control Services Limited ("ICS" or "Petitioner") hereby submits this petition to recognize and enforce a foreign arbitration award pursuant to the Convention on the Recognition and Enforcement of Foreign Arbitral Awards, June 10, 1958, 21 U.S.T. 2517 (the "New York Convention"), as statutorily enacted by Chapter 2 of the Federal Arbitration Act ("FAA"), see 9 U.S.C. §§ 201, 207.

Specifically, ICS seeks recognition and enforcement of a final, binding arbitration award (the "Award") in favor of ICS and against Respondent the Argentine Republic ("Argentina"), issued on April 29, 2024, by a duly constituted arbitral tribunal (the "Tribunal") seated in The Hague, The Netherlands. The Tribunal, proceeding under the Rules of the United Nations Commission on International Trade Law ("UNCITRAL"), unanimously held Argentina liable to pay damages for violating Article 2 of the bilateral investment treaty between the Government of the Republic of Argentina and the Government of the United Kingdom of Great Britain and Northern Ireland for the Promotion and Protection of Investments, dated December 11, 1990 (the "BIT"). Argentina's breach of the BIT arose from measures it took in relation to ICS's investment, including conduct concerning a March 11, 1998 agreement (the "Contract") between ICS and Argentina's Ministry of Economy and Public Finances, the Ministerio de Economía y Finanzas Públicas de la República Argentina (formerly Ministerio de Economía y Obras y Servicios Públicos) ("MECON").