Recognition of Foreign Judgments in the United States (VIDEO)
In the current economic climate, it is important that lenders understand how they can enforce security and debt claims, to help in assessing options in the event of default by their customers, and when structuring new...more
On 7 December 2023, the Court of Justice of the European Union (CJEU) issued a landmark judgment on Article 22 of the General Data Protection Regulation (GDPR), focused on decision making based solely on automated processing...more
German real estate company Adler recently made headlines by successfully implementing a €6bn restructuring by way of a UK Part 26A Restructuring Plan. The Plan involved the subordination of Adler’s existing notes to new money...more
On April 24, 2023, the EU Council announced that it will seek treaty relations with Ukraine under the framework of the 2019 Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial...more
Sun Vessel Global Limited (Appellant) v (1) HQ Aviation Limited, (2) Great Lakes Insurance (UK) SE (Respondents) Judgment given on 9 January 2023. Court’s Jurisdiction to reconsider matters before delivery of its perfected...more
On March 1, 2022, the United States became the sixth State to sign the 2019 Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters (“Judgments Convention”). If ratified, the...more
On 31 December 2020 the Brexit Transition Period ended. Although the UK and EU have agreed some elements of their future trading relationship in the EU-UK Trade and Cooperation Agreement, this does not make long-term...more
Will the UK join the Lugano Convention 2007? Conflicting reports have emerged in recent days as to whether the EU will approve the UK’s application to join the Lugano Convention 2007, the UK’s preferred regime for...more
The 2019 Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters offers certainty in cross-border enforcement of judgments. On 2 July 2019, the Hague Conference on Private...more
On 6 March 2018 the Court of Justice of the European Union (“CJEU”) issued its judgment in Case C-284/16 Slovak Republic v Achmea BV. The CJEU ruled that investor-State arbitration clauses in investment treaties concluded...more
In Google LLC v. Equustek Solutions Inc.,1 a United States district court enjoined the enforcement of an order by the Supreme Court of Canada that directed Google to remove content from Google search results. The Canadian...more
The EU has taken aim at fraudulent or abusive forum shopping in the Recast Insolvency Regulation, acknowledging the potential for misuse by debtors seeking to take advantage of more flexible insolvency processes available in...more
Enforcing judgments expeditiously across borders is critical for multinational businesses. It is important to understand whether cross-border enforcement is practicable before pursuing proceedings. The EU has legislation...more
In a highly integrated economy like Europe’s, cross-border litigation is common. Oftentimes, a suit may be brought in a court in one EU country against a defendant with assets in many EU countries, so that a judgment from...more
On Thursday 23 June 2016, the UK electorate voted to leave the European Union. While this vote was advisory in nature, we expect that ultimately the UK Government and Parliament will respect the outcome and serve notice to...more
Civil proceedings brought by the state or a state entity are one mechanism to recover the proceeds of corruption, or to claim compensation for corrupt acts. Typically, substantial corruption cases are international in...more
UK Supreme Court decision confirms traditional rules on enforcement of all US judgments in England and reverses a significant liberalisation of cross-border bankruptcy law....more