Following the Achmea Judgment, in which the CJEU ruled in 2018 that arbitration provisions contained in international agreements between Member States are precluded by EU law, the CJEU recently rendered, in a span of just six months across 2021 and 2022, three subsequent judgments in the Komstroy, PL Holdings, and Micula matters. This article explains how those three judgments constitute a methodical exercise by which the CJEU seeks to close the door to attempts to circumvent the Achmea Judgment. The article analyses how the three judgments contain at the same time confirmations of what was already known from the Achmea Judgment, but also clarifications as to the state of EU law on this topic. The article also discusses the concrete effects of the three judgments on the investor protection landscape in the EU, and the questions that intra-EU investment tribunals may now need to address.