An UNCITRAL tribunal in Geneva has declined jurisdiction over a US $185 million investment treaty against Venezuela brought by a Spanish subsidiary of US cleaning products group Clorox. It found that Clorox España did not have a protected investment under the Spain-Venezueal bilateral investment treaty. GST LLP partner Ignacio Torterola tells GAR: “The tribunal has affirmed the rule in investment arbitration that a transfer of shares without consideration is not a protected investment.”