Until recently, requests for security for costs (SfC) were relatively rare. Earlier cases that dealt with SfC applications imposed a high threshold that may have had a deterrent effect on States. Although tribunals have remained reluctant to grant such requests, there has been a gradual rise in the number of SfC applications made by States. This emerging trend may be partially due to the growing use of third-party funding by thinly capitalized investors. Although tribunals have traditionally been unmoved by this, several developments suggest that the landscape may be changing.

中文翻译：

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Herzig 诉土库曼斯坦案¹要求在涉及第三方资助的破产申请人的 ICSID 仲裁中提供费用担保

直到最近，对成本安全 (SfC) 的请求还比较少见。早期涉及 SfC 申请的案件设置了高门槛，可能对各国产生了威慑作用。尽管仲裁庭仍不愿批准此类请求，但各国提出的证监会申请数量已逐渐增加。这种新兴趋势可能部分是由于资本薄弱的投资者越来越多地使用第三方资金。尽管法庭传统上对此不为所动，但一些发展表明情况可能正在发生变化。