From Sanitek to ICSID: Lawyer who Argued Against Armenia Selected as Its International Arbitrator
Armenia has changed the composition of its arbitrators and mediators at the International Centre for Settlement of Investment Disputes (ICSID) for the next six years.
Hetq’s investigation shows that the lawyers nominated under the state quota have various connections to Karen Andreasyan, the Prime Minister’s Office’s representative for international legal issues, through professional, business, or personal relationships, and their selection process was not public.
The ICSID is an international arbitration institution established in 1966 for legal dispute resolution and conciliation between international investors and States. ICSID is part of and funded by the World Bank Group.
In February 2026, Karen Andreasyan presented four candidates to ICSID for a term of office until February 4, 2032. The nominees were Yeghishe Kirakosyan, former head of the International Legal Representative’s Office; Grigor Minasyan, former Minister of Justice; Haykuhie Harutyunyan, former chair of the Commission for the Prevention of Corruption; and Sargis Grigoryan, founding director of G Partners. The latter represented the company's interests as part of the legal team in the case of Sanitek (Sanitek S.a.r.l.) against Armenia, which is being heard at the same center. All the candidates presented have already been included in the ICSID panels of arbitrators and conciliators.
Sargis Grigoryan was presented to the international center at a time when a judgment had not yet been rendered in the Sanitek case (the judgment was rendered on May 22, 2026, and on April 24 of the same year the tribunal declared the proceedings closed).
What is the connection between the appointed arbitrators/mediators and Karen Andreasyan and how they were selected?
The former Armenian Minister of Justice Grigor Minasyan (who served from December 26, 2022 to October 2, 2024, replacing Karen Andreasyan), is a shareholder and director of the AM law firm. Eva Arakelyan, the wife of Karen Andreasyan, the head of the Office of the Representative for International Legal Affairs, is also a shareholder in the same firm.
The media and the legal community in Armenia actively discussed the connection and possible conflict of interest between the Minasyan and Andreasyan families back when Karen Andreasyan held the position of President of the Supreme Judicial Council (SJC) of Armenia and Grigor Minasyan was the Minister of Justice. At that time, the SJC made decisions to subject judges to disciplinary action based on the ministry’s motions.
Thus, even after the change of officials, the business connections between the families of high-ranking officials are preserved. The candidate representing the state in an international court was nominated by the official whose wife is the business partner of the person in question. Such a situation raises reasonable doubts about the independence, impartiality, and public trust in the decisions.
Yeghishe Kirakosyan and Haykuhie Harutyunyan also have friendly relations with Karen Andreasyan. Haykuhie Harutyunyan works at the AM law firm of Karen Andreasyan’s wife and Grigor Minasyan, where she is a senior legal advisor.
The adoption of the Convention “On the Settlement of Investment Disputes between States and Nationals of Other States” established the International Centre for the Settlement of Investment Disputes. The latter has committees of conciliators and arbitrators. Each state that has ratified the Convention is entitled to nominate four people to each committee for a term of six years.
According to the Convention, people nominated as members of the panels must be of high moral character and recognized as competent professionals in the fields of law, trade, industry or finance, whose independent judgment can be relied on. Legal specialization is of particular importance, especially for members of the panel of arbitrators.
The seat of the Centre is located at the headquarters of the International Bank for Reconstruction and Development (Washington).
The Office of the Representative for International Legal Affairs reported that it had received a total of four applications for nomination by the Republic of Armenia to the panels of mediators and arbitrators of the International Center for Settlement of Investment Disputes (ICSID). The terms of office of the previous members expired on January 24, 2026.
According to the Office’s Chief of Staff Artyom Sujyan, the nomination process for candidates was conducted in accordance with the Law “On the Representative for International Legal Affairs” and the regulations of the Office of the Representative. By law, the representative is authorized to propose candidates for arbitrators and mediators to be appointed by the Republic of Armenia to the International Center for Settlement of Investment Disputes. For this purpose, all four applications received were studied and analyzed, and the corresponding nominations were made.
Hetq asked Karen Andreasyan, the Representative of the Prime Minister’s Office for International Legal Affairs, in writing, how, by what criteria, and by whom the candidates for arbitrators and mediators were selected. The response received does not actually provide answers to these questions.
There was no competition for the selection of candidates, as is the case with candidates for judges of the European Court of Human Rights. There is no such regulation either. Here, the Representative for International Legal Affairs, in this case Karen Andreasyan, has great discretionary powers.
However, the lack of regulation is not at all an obstacle to starting an open and public process. In the absence of an announcement, how was the professional community informed about the possibility of nominating candidates, by what criteria were the applicants evaluated, were interviews or a comparative assessment of the candidates conducted, and why were these individuals selected? There was also no additional application for selection, so that there was an opportunity to choose among the applicants.
There was no announcement in open sources, including on the Facebook page of the Office of the Representative for International Legal Affairs, about the nomination of an arbitrator or mediator. The written response of the Chief of Staff of the Office of the Representative also did not mention the announcement.
Moreover, if all four applicants submitted were nominated, the question arises as to why the applications were examined and evaluated at all if no candidate was rejected because of that process. It is in this context that the question arises as to why the Republic of Armenia decided to nominate to the panels of conciliators and arbitrators of the International Center for Settlement of Investment Disputes the lawyer who represented the interests of the Republic of Armenia's procedural opponent in the same arbitration in a case that has not yet been decided.
The four nominated individuals (Yeghishe Kirakosyan, Grigor Minasyan, Sargis Grigoryan and Haykuhie Harutyunyan) submitted their CVs to the Office of the International Legal Representative, based on which the candidates were selected.
Hetq asked the International Legal Representative in writing about the conflict of interest, to which they replied that there was no conflict of interest.
“The above situation cannot in itself be considered as a circumstance excluding the nomination of a candidate, since the opposite approach would lead to the automatic exclusion of the candidacies of specialists who have ever represented the Republic of Armenia in the framework of any lawsuit (complaint) ever filed against it, including complaints filed against it at the European Court of Human Rights. We also consider it necessary to state that at the time of the submission of the aforementioned candidacy, the examination of the arbitration case of Sanitek and others against Armenia was fully completed and had passed the stage of making and publishing the award,” Artyom Sujyan, Head of the Office of the Representative of Armenia for International Legal Affairs, told Hetq.
The question is not whether a person who previously represented Armenia can or cannot be nominated to ICSID panels. The real issue is not a formal conflict of interest, but external perception.
In May 2021, an article penned by Sargis Grigoryan was published in Armenia’s media, which, referring to the Sanitek case, noted that the company’s claim amounted to more than US$25 million, which is the result of the joint unprecedented expropriation (confiscation) “efforts” of the Government and the Yerevan Municipality. In total, claims of more than US$1.5 billion have been filed against Armenia by various foreign investors.
“It is an undeniable fact that the current government does not have sufficient capacity to create a favorable investment environment or adopt an investment policy that would allow it to attract foreign investment, among other things, to boost the country’s post-war economy. Moreover, since 2018, because of the government’s actions (or inaction), some major foreign investors have abandoned their projects altogether, and some have filed international lawsuits against Armenia,” Grigoryan wrote.
Grigoryan told Hetq that for the past twenty years he has been engaged only in investment and commercial arbitration. His specialization in law is investment arbitration.
When asked how he learned about the vacancies for arbitrators and mediators that Armenia was to represent, he said that the list is published on the ICSID website, and it is possible to see who the arbitrators from Armenia are and the expiration of their terms of office.
According to Grigoryan, he sent a self-nomination application and a resume to the Office of the Representative for International Legal Affairs of the Prime Minister's Office, asking them to consider his candidacy as an arbitrator, if such an opportunity arises. He said his work experience, education, and professional qualifications met the requirements set for arbitrators by the ICSID Convention and the Rules of Procedure.
Grigoryan said that he is not a friend of Karen Andreasyan, and they do not communicate. They met at an event some fifteen years ago.
“There is no need to find a scheme here because I think that in investment arbitration in Armenia and regionally, I have no competition. There is no need to look for anything else because the terms of four former arbitrators were ending and I thought there was an opportunity,” Grigoryan said.
Hetq also asked Grigoryan how it happened that in one case in the same investment arbitration he acted against the Republic of Armenia, defending the interests of the Sanitek company, but before the verdict was published, Armenia nominated him for the position of arbitrator.
He noted that there is no conflict of interest here. As to who you represent and when you represent is not one of the requirements for the appointment of ICSID, Grigoryan added, because justice, especially in international arbitration, excludes such things. In other words, access to justice is available to everyone.
“I have done my job, I have represented the interests of the client in this arbitration court, and I represent other clients outside of Armenia in other international courts. If you look at the ICSID website, you will see when the Sanitek case was closed. You just looked at the date of publication of the judgment,” said Grigoryan.
We wondered if he had the same opinion about the Armenian government, which hinders international investments in the country. Grigoryan said that in 2026 Armenia adopted a law on foreign investments, by which it completely revised its legislative framework, legal regulations, guarantees that it provides to foreign investors, etc. Grigoryan believes these changes have significantly changed the investment environment in terms of investment protection.
“If the legislation is not properly implemented, we will talk together, we will continue our discussion. But if it is implemented, it means that the legislation is in effect. I think we need to give time for the legislative tools adopted by the National Assembly and the government to be implemented," Grigoryan told Hetq.
Armenia’s former arbitrators
Prior to February 4, 2026, Armenia was represented at the International Centre for Settlement of Investment Disputes by prominent American-Armenian lawyers Grant Hanessian and Thomas Samuelian; lawyer, international law specialist Levon Gevorgyan; and former Representative for International Legal Affairs Yeghishe Kirakosyan. Their office terms expired on January 24, 2026.
It is worth noting that Grant Hanessian, as part of the international team of lawyers of the Republic of Armenia (also Victor Dumler and Hayk Hovhannisyan), secured a victory for Armenia in the arbitration case (Rasia FZE and J. Borkowski v. Republic of Armenia). The team of lawyers managed to achieve that the Arbitration Tribunal, by its award, ordered Armenia to compensate for all legal expenses incurred because of the claims, in the amount of 2.8 million USD. As a result, the investment company “Rasia FZE” and its American CEO Joseph Borkowski not only did not receive the requested approximately 331 million USD, but also suffered losses, compensating Armenia for legal expenses.
Thomas (Tom) Samuelian is an Armenian-American lawyer, linguist, and translator. He has been engaged in international law, legal reform, and human rights issues for nearly three decades. He is the co-founder of the law firm Arlex International and has taught and held leadership positions at the American University of Armenia for many years.
Levon Gevorgyan is a Doctor of Law. He acted as a representative for Armenia in the case concerning the International Convention on the Elimination of All Forms of Racial Discrimination (CERD) brought by Armenia against Azerbaijan, currently pending before the UN International Court of Justice (ICJ).
Yeghishe Kirakosyan is a specialist in public international law and a candidate of legal sciences and an attorney. From 2020 to 2025, he held the position of Armenia’s Representative on International Legal Affairs, representing the country at the UN International Court of Justice (ICJ), the European Court of Human Rights (ECHR), as well as in international arbitration proceedings.
The essence of the issue is not the professional expertise of the nominees, but why the Armenian government fails to choose a more open and competitive path in the case of decisions of international significance. No matter how high-quality the candidates are, the lack of a transparent procedure is enough to undermine public trust in this process.
Photo (from left): Karen Andreasyan, Sargis Grigoryan
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