Even though Nigeria has been on the receiving end of relatively few investment treaty lawsuits from investors at international arbitration tribunals, it has joined the growing number of countries that are critical of the current international arbitration system. The Nigerian government has recently initiated a reform process of its international investment agreements. In 2016, it developed a new model for its future bilateral investment treaties, which includes some innovative features but maintains the much criticised Investor State Dispute Settlement (ISDS) process.