This document is a formal demand letter submitted by counsel for the Claimants to the Republic of Romania, seeking immediate payment of the sums awarded in the final Award dated 20 February 2024 in ICSID Case No. ARB/18/19. The correspondence serves as a formal notice of the Claimants' intent to enforce the Award should voluntary compliance not be forthcoming.

In the letter, the Claimants emphasize that pursuant to Article 53(1) of the ICSID Convention, the Award is final and binding upon Romania. Relying on calculations performed by their quantum experts, the Claimants quantify the total outstanding obligation—comprising the principal compensation, arbitration costs, defense expenses, and compounded post-award interest—at €52,071,561 as of the date of the demand. The Claimants further note the continuing daily accrual of interest on the principal sum and defense expenses.

The correspondence concludes with a strict demand for payment to a specified trust account within fifteen days. The Claimants expressly reserve all rights under the Award, the ICSID Convention, and applicable laws, warning that failure to remit payment by 31 May 2024 will result in the initiation of legal measures in competent jurisdictions to enforce the Award and recover all outstanding amounts.