Cross-Border Insolvency: COMI, Jurisdiction, Recognition and Conflicting Proceedings

This ARGA Observatory report examines cross-border insolvency through the determination of the centre of main interests (COMI), jurisdiction, recognition and the scope of assistance available to foreign proceedings. It compares the European framework, the UNCITRAL Model Law, US Chapter 15, and approaches in England and Wales and France. Eight judicial decisions and six hypothetical scenarios address corporate authority, creditor claims, immovable property, criminal asset restraints and group coordination. The report connects procedural choices with the practical costs and prospects of recovery. This publication includes the Russian and English versions.