Illustrative Suggestions for Amendments to the ICSID Arbitration Rules

CCSI submitted comments to the ICSID Secretariat of the World Bank. While not comprehensive, our comments briefly highlight some issues that we believe need to be addressed on a priority basis in order to help address some of the gaps regarding
the legitimacy and fairness of investor-state arbitration. This submission is not meant to be exhaustive.

Our comments cover:

• Recognizing and safeguarding the rights and interests of non-parties
• Improving transparency of the dispute resolution process
• Promoting transparency of ownership
• Preventing abuse of requests for interim measures
• Preventing actual and apparent conflicts of interest
• Addressing concerns raised by third-party funding
• Ensuring legitimacy of settlement agreements
• Ensuring legitimacy of the rule revision process