In recent years direct expropriation of investments of foreign investors was seen rarely. However, expropriation has by no means vanished: its execution has just become more subtle. Ambiguous or generously worded laws are “interpreted” to the detriment of investors, administrative discretion is influenced or the administrative bodies fail to act in a transparent manner. Can the legal order of developing countries live up to the standards required by international investment agreements? The authors undertake a disenchanting comparative analysis based largely on provisions of Russian law.