The recent case of Ascentra Holdings, Inc v. SPGK Pte Ltd [2023] SGCA 32 (Ascentra) has drawn a line in the sand in the Singapore court's interpretation of the UNCITRAL Model Law on Cross-Border Insolvency (UNCITRAL Model...more
The model law aims to maximise group-wide recoveries in an insolvency through cooperation and efficient administration. The UK government has announced its intention to legislate to implement the UNCITRAL Model Law on...more
On July 7, 2022, the UK Insolvency Service, an executive agency of government responsible for a variety of roles in administering the UK insolvency regime, published a consultation on the UK’s proposed adoption of two...more
On 13 June 2019, the much anticipated DIFC Insolvency Law No. 1 of 2019 and associated DIFC Insolvency Regulations 2019 (collectively the “2019 DIFC Insolvency Law”), came into full force and effect, replacing the DIFC...more
In December 2018, at its 54th session in Vienna, Working Group V (Insolvency Law) of the United Nations Commission on International Trade Law (UNCITRAL) discussed revisions to its Enterprise Group Insolvency: Draft Model Law...more
David Conaway reports on a ruling by the English High Court in late 2018 that impacted the US Chapter 11 proceedings in Delaware. Originally published in Eurofenix, Spring 2019. ...more
The Situation: In Bakhshiyeva v Sberbank of Russia, a debtor sought to restructure English law-governed debts pursuant to an Azerbaijani restructuring proceeding. In order to prevent certain dissenting creditors from...more
On September 18, 2018, the United Nations Commission on International Trade Law ("UNCITRAL") published its final version of the new Model Law on the Recognition and Enforcement of Insolvency-Related Judgments (the "IRJ Model...more