The claimant argued that, because it had assets within a convention country, it was inappropriate or unnecessary to order security. The assets the claimant claimed to have were: (i) 99% of the shares in a Swiss-incorporated company (TOAG) worth CHF 453,273,431, which were held in bearer form in a safe deposit box in Switzerland; and (ii) 100% of the shares in a Cypriot company (Tatneft Finance) which had current assets of about US$9 million and non-current assets of about US$170 million.