Foreign companies have lately resorted to arbitration in international trade tribunals in total disagreement with Salvadoran government policies. In 2008, El Salvador sought international arbitration against Italy's Enel Green Power, on behalf of Salvadoran state-owned electric companies for a geothermal project Enel had invested in. Four years later, Enel indicated it would seek arbitration against El Salvador, blaming the government for technical problems that prevent it from completing its investment. The government came to its defence claiming that Art 109 of the constitution does not allow any government (regardless of the party they belong), to privatize the resources of the national soil (in this case geothermic energy). The dispute came to an end in December 2014 when both parties came to a settlement, from which no details have been released. The small country had yielded to pressure from the Washington-based powerful ICSID. The U.S. Embassy warned in 2009 that the Salvadoran government's populist policies of mandating artificially low electricity prices were damaging private sector profitability, including the interests of American investors in the energy sector. The U.S. Embassy noted the corruption of El Salvador's judicial system and quietly urged American businesses to include "arbitration clauses, preferably with a foreign venue", when doing business in the country.