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2 Jun 2025
Insight
In today’s increasingly interconnected financial landscape, cross-border restructurings demand a nuanced understanding of legal frameworks across jurisdictions. This guide offers a comparative overview of the key themes in the five major centres of bankruptcy and restructuring: the United States, United Kingdom, Hong Kong, Singapore, and Australia. Drawing on the combined capability of local practitioners, the article explores eligibility thresholds, jurisdictional strategies, recognition mechanisms, and recent case law developments that shape how debtors and creditors navigate complex, multi-jurisdictional bankruptcy and restructuring scenarios.
Key contacts
John Whiteoak
Partner, London
Amy Caton
Managing Partner, Finance and Restructuring, US and Head of Bankruptcy and Restructuring, US, New York
Kenneth H. Eckstein
Partner, Head of Bankruptcy and Restructuring, US, New York
Kevin Pullen
Partner, London
Jojo Fan
Managing Partner, China Offices, Hong Kong
William Ku
Partner, Hong Kong
Daniel Chia
Managing Director and Head of Litigation, Singapore
Paul Apáthy
Partner, Sydney
Legal Notice
The contents of this publication are for reference purposes only and may not be current as at the date of accessing this publication. They do not constitute legal advice and should not be relied upon as such. Specific legal advice about your specific circumstances should always be sought separately before taking any action based on this publication.
© Herbert Smith Freehills Kramer 2026