Petitioner the Republic of Argentina (“Argentina”), by its attorneys, Cleary Gottlieb Steen & Hamilton LLP, respectfully submits this petition to vacate an arbitral award rendered against it and in favor of respondent AWG Group Ltd. (“AWG”).

PRELIMINARY STATEMENT

1. The arbitral award at issue arose from an arbitration (the “Arbitration”) brought under the bilateral investment treaty between the United Kingdom and Argentina. Agreement Between The Government of the United Kingdom of Great Britain and Northern Ireland and The Government of the Argentine Republic for the Promotion and Protection of Investments, UKArg., Dec. 11, 1990, 1765 U.N.T.S. 34 (the “Argentina-UK BIT” or the “BIT”). AWG, a national of the United Kingdom, claimed that its rights under the BIT in respect of an investment in a public utility concession in Argentina were breached by measures taken by the government of Argentina to address the worst economic, political, institutional, financial, and social crisis in the country’s history. The arbitral tribunal agreed and awarded AWG approximately $20 million.