This paper is the result of a comparative analysis of investment treaties, investment arbitration awards, subject literature and expert interviews. It investigates options for integrating the strong legal regime of investment arbitration which brings together the principal actors in transnational corruption: foreign investors and host states further into the fight against corruption. Investment arbitration jurisprudence shows that host states have made allegations of bribery with an increasing frequency. However, the lack of unambiguous guidelines on how to treat such arguments has arguably contributed to a shortage of affirmative decisions, even where further evidence might have been available.
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