The DTEK Scheme: A New Way to Restructure US Law Bonds?

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Double First: A Ukrainian group of companies breaks ground — first by changing the governing law of its high yield bonds from US to English law and then by being the first Ukrainian-based group to restructure via an English law scheme of arrangement -

The Debate: Chapter 11 vs Scheme of Arrangement -

The restructuring market has for some time been engaged in a spirited debate about the appropriate forum in which to restructure US law governed high yield (HY) bonds issued by European and American corporates. Which is more appropriate, in the US by way of a Chapter 11 or London via the scheme of arrangement?

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