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Investment treaty awardUnpaid

Cengiz İnşaat and Etrak İnşaat v. Libya

Construction projects halted in 2011

Headline amount
$80.1MEstimate
Respondent
LibyaState
Awarded
2018Etrak award later
Status
UnpaidNothing collected

Latest development Mar 10, 2026

A Curaçao court refused recognition of a related award.

The award

Amount awarded
About $50M (Cengiz) and $30.1M (Etrak judgment)
Award holder
Cengiz İnşaat and Etrak İnşaat (Turkey)
Respondent
State of Libya
Forum
ICC (Cengiz, 2018) · Swiss-seated treaty arbitration (Etrak)

Challenges

The Cour de cassation rejected Libya’s annulment bids against the Cengiz award on February 12, 2025.

Enforcement

United States: the D.D.C. confirmed the Etrak award on February 4, 2025 ($30.1M with interest) and denied Libya’s stay request. In December 2025 it allowed attachment of Libyan assets toward the judgment. Curaçao refused recognition of a related $20M Turkish ICC award and held the attached assets immune (March 10, 2026).

Recovered to date

None reported

Notes

Two awards combined. The Curaçao ruling concerns a related award.