The International Centre for Settlement of Investment Disputes (ICSID), a World Bank arm for investor-state dispute arbitration, ruled in March that “unless there is agreement of the parties on the issue of confidentiality and transparency, the Tribunal shall decide on the questions of confidentiality and transparency on a case-by-case basis, instead of tending towards imposing a general rule in favour or against confidentiality.” This decision expressly rejects the new Bank transparency policy, which includes a presumption of disclosure for documents (see Update 68).