In Metal-Tech Ltd. v. Republic of Uzbekistan—a dispute arising under the Israel-Uzbekistan bilateral investment treaty (BIT) relating to a joint venture to process minerals—an International Centre for Settlement of Investment Disputes (ICSID) tribunal found that it lacked jurisdiction to hear the claim as the initial investment failed to fulfill the requirements of Article 1(1) of the BIT, which provides that the investment be “implemented in accordance with the laws and regulations of the Contracting Party in whose territory the investment is made.” The tribunal concluded that “corruption was established to an extent sufficient to violate Uzbekistan law in connection with the establishment of the Claimant’s investment in Uzbekistan,” and since Uzbekistan’s consent to ICSID arbitration is restricted to disputes concerning investment implemented in compliance with local law, the dispute failed to fulfill Article 8(1) requirements. The tribunal dismissed all other claims and counterclaims, and it held that each party should bear its own costs.