On July 11, 2017, the Second Circuit Court of Appeals issued Mobil Cerro Negro Ltd. v. Bolivarian Republic of Venezuela, holding that the Foreign Sovereign Immunities Act (the “FSIA”) is the sole basis for jurisdiction over a foreign state in U.S. court actions to enforce awards issued pursuant to the International Convention on the Settlement of Investment Disputes between States and Nationals of Other States (the “ICSID Convention”).