Although the responsibility to refrain from acts of bribery and corruption is not referenced explicitly in the ICSID Convention, allegations of bribery and corruption are increasingly common in Investor-State arbitration. Many tribunals have remarked on the standard and burden of proof applicable to corruption allegations, but very few tribunals have had occasion to analyze the consequences of a finding of corruption. The questions to be answered include whether corruption should be addressed as a matter of jurisdiction or together with the merits of the case; whether a host State’s recourse to corruption defense is subject to waive or estoppel; and whether there is any basis for tribunals to evaluate the comparative culpability of the parties with respect to corrupt transactions. A few tribunals have addressed the corruption issues differently, including World Duty Free Co. v. Kenya, Niko Resources v. Bangladesh, Metal-Tech v. Uzbekistan, which reflect the development of jurisprudence on this topic.