I. Introduction

1. In accordance with Article 8 of the Agreement between the Government of Barbados and the Government of the Republic of Venezuela for the Promotion and Protection of Investments (the “Treaty”),1 Blue Bank International & Trust (Barbados) Ltd. (“Blue Bank”),2 a Barbados corporation, as trustee of the Qatar International Authorised Purpose Trust (“Qatar Trust”), submits to arbitration at the International Centre for the Settlement of Investment Disputes (“ICSID”) certain claims against the Bolivarian Republic of Venezuela (“Venezuela”), as established further below.

2. Blue Bank and its representatives, affiliates, and agents in Venezuela invested far in excess of one hundred million dollars (US$100,000,000.00) as part of its efforts to rehabilitate numerous tourism and hospitality facilities throughout Venezuela for which it was granted concessions to develop and to operate.3 Specifically, through a series of intermediary entities,4 Blue Bank and its representatives, affiliates, and agents in Venezuela were granted concessions relating to (i) the Sistema Teleférico Caracas (the “Teleférico”), an elaborate elevated cable car system that connects the urban core of Caracas, the Venezuelan capital, with the heights of the Ávila Mountain Range, which in approximately 1955 were developed as a tourist and recreation zone; (ii) the Hotel Humboldt, a vast and stately hotel located in the mountains at the terminus of the Teleférico; and (iii) the Gran Hotel de Puerto la Cruz in the State of Anzoátegui (“Hotel Puerto La Cruz”), a luxurious seafront hotel (collectively, the “subject properties”). All of these properties were in a severe state of disrepair and abandonment at the time the concessions were granted. Therefore, their renovation was a central motive for the public bidding process that Venezuela promoted and published to the known universe of prospective investors.