A tribunal has declared that Clorox España is disqualified from seeking damages against Venezuela, due to the fact that it is a shell company created to take advantage of a bilateral investment treaty (BIT) in place between Spain and Venezuela. The Clorox company owned its Venezuelan investments through an American subsidiary, explained GST LLP Partner Diego Gosis. He applauded the ruling, saying the decision confirms the long-standing view in international law that “to access the protections granted by the investment arbitration system, a meaningful, qualified investment must actually have been made.”