Most of the investment chapters and treaties in force today contain investor–state arbitration provisions allowing investors to initiate direct actions through international arbitrations against host states to enforce their rights (ISDS). ISDS has been widely criticized over the years for its unpredictability and lack of transparency. Through such provisions, the foreign investor is given rights and remedies not available to domestic investors, in an international process that is largely devoid of the safeguards that exist in domestic courts. Many private investors have relied on such provisions and launched challenges to legitimate environmental laws or other public welfare measures and obtained compensations from host states for breaching their treaty obligations.