Led by our founding partner, recognized by Chambers & Partners (Band 1, Asset Tracing & Recovery, Global-Wide). ICC FraudNet member. Pursuing and recovering assets worldwide Asset Recovery Sequor Law is recognized worldwide for its leadership in the practice area. We not only recover assets for victims of fraud and corruption, but also seek to hold aiders and abettors, conspirators, and facilitators liable through third-party actions. From Investigation to Repossession: A Full-Spectrum Recovery Practice Sequor Law is uniquely focused on pursuing and recovering client assets and value for the client at every phase of the dispute, from investigation and strategic case development through litigation, arbitration, pre-judgment remedies, and enforcement. Every day, we rise to meet the increasingly sophisticated methods used to conceal, transfer, or launder assets across jurisdictions. Sequor Law pioneered the concept of “value recovery,” advancing beyond the traditional model of Asset Recovery limited to freezing and recovering tangible assets. Our focus is not solely on the assets themselves, but on maximizing total recoverable value. This includes pursuing claims against aiders and abettors, conspirators, and facilitators through direct third-party actions. Drawing on extensive experience in complex Asset Recovery matters, the firm has successfully recovered value in a wide range of scenarios, including claims arising from contracts procured through fraud or corruption, the exercise of restitution rights in criminal proceedings, the reopening of matrimonial settlements, and the enforcement of Judgments previously considered uncollectible. Fraudsters and corrupt actors frequently employ layered corporate structures, offshore vehicles, and multi-jurisdictional transfers to obscure beneficial ownership and move assets rapidly beyond reach. Addressing these schemes requires technical sophistication, deep knowledge of multiple legal systems, and sustained strategic execution. Sequor Law brings all three. Our team operates seamlessly across common law and civil law jurisdictions, allowing us to act quickly and effectively in complex cross-border environments. The firm’s Asset Recovery practice is focused on penetrating the inner circle of the wrongdoer and dismantling the structures used to shield assets. We deploy a full suite of legal tools, including asset freeze orders, pre-judgment remedies, advanced evidence-gathering mechanisms, insolvency proceedings, and direct claims against both wrongdoers and third-party facilitators. Piercing Complex Structures to Reach the Wrongdoer's Inner Circle Recognized Global Leaders Who Shaped an Entire Practice Area Sequor Law’s attorneys were instrumental in developing Asset Recovery as a globally recognized legal practice and continue to lead its evolution as new technologies and increasingly complex schemes emerge. The firm is consistently ranked among the leading practices worldwide in Asset Tracing & Recovery by Chambers & Partners and the Lexology Index. Sequor Law has also been recognized as Asset Recovery Firm of the Year, reflecting its sustained leadership in the field. Founding Shareholder Edward H. Davis, Jr. has been consistently ranked Band 1 globally by Chambers & Partners for Asset Tracing & Recovery, including most recently in 2025. He was also named Asset Recovery Lawyer of the Year by Who’s Who Legal in multiple consecutive years, underscoring the firm’s leadership at the highest level of the practice. There is no one-size-fits-all solution in Asset Recovery. Each matter requires a tailored strategy based on the facts, the jurisdictions involved, and the client’s objectives. Sequor Law is committed to identifying that strategy and executing it with precision, persistence, and a relentless global focus on securing results. Representative Representative Cases One of the Largest Ponzi Schemes in History Sequor Law represents the Joint Liquidators for Stanford International Bank, Ltd. (“SIB”) (in Liquidation). SIB, a bank located in Antigua that primarily sold certificates of deposit, played a central role in a worldwide Ponzi scheme, the second largest in history, perpetrated by Robert Allen Stanford, with losses to depositors estimated to exceed US$4.4 billion. Since May 12, 2011, when Marcus Wide and Hugh Dickson of Grant Thornton were appointed Joint Liquidators of the SIB estate in Antigua, Sequor Law has acted as co-general counsel with Caribbean counsel in global Asset Recovery efforts that have included recovering US$3.2 million from Panama, US$20 million from the United Kingdom, freezing assets in Antigua & Barbuda valued at US$212 million, launching a formal claims process, pursuing claims related to approximately US$330 million in frozen assets in Canada, Switzerland, and the U.K., filing damages claims valued at approximately US$5 billion against a Canadian bank, and initiating recovery efforts in Colombia against law firms and financial institutions. Sequor Law also initiated a Chapter 15 recognition proceeding in Dallas, Texas, and later helped the U.S. Judicial Administrator, the SEC, the U.S. Department of Justice, the Joint Liquidators, and others reach a global agreement and cross-border protocol. Recognition and Enforcement of UK Worldwide Freezing Order Sequor Law represents Novoship (UK) Limited and affiliated entities in a Judgment domestication and enforcement matter in Florida. After Novoship obtained approximately US$98 million in Judgments from the English High Court of Justice against a Venezuelan national and his companies for fraudulent acts relating to charter party contracts, and after the debtors breached a US$40 million settlement, Sequor Law obtained recognition of the English freezing injunction in Florida within 24 hours. The firm froze assets, commenced discovery before full recognition of the English Judgments, and uncovered nearly US$3.5 million in local bank funds and approximately US$1.5 million in Florida real estate. Coordinated proceedings in Florida, Switzerland, and London resulted in payment of the full settlement amount. Judgment Enforcement Against Sovereign in Bond Default Case Since 2008, Sequor Law has represented two major creditors of the Republic of Argentina in pursuing collection of more than US$1 billion in Judgments in Florida arising from Argentina’s 2001 bond default. Working with New York counsel, the firm pursued collection from assets located in Florida, including assets at the Miami office of Banco de la Nación Argentina, a bank wholly owned by the Argentine government. Representation of a Class of More Than 2,000 Victims of Caribbean Fraud Sequor Law represented a class of 2,232 victims of the Leadenhall Bank & Trust and Cash-4-Titles fraud in the British Virgin Islands and The Bahamas and recovered US$14.4 million. After Leadenhall entered liquidation and was sued in the U.S. District Court in Miami, the class obtained a final money Judgment of US$313 million in September 2007. Enforcement of that Judgment resulted in the US$14.4 million recovery, with approximately US$7 million more to be distributed thereafter. Proceedings Supplementary in Aid of Judgment Enforcement Sequor Law represented Robert J. Lodge and Robert K. Orr against SunTrust Bank. After obtaining an order for proceedings supplementary in aid of execution and conducting extensive discovery and depositions, the matter concluded in a favorable settlement in which significant funds were recovered by the Judgment creditor’s successor-in-interest. Deployment of International Treaties and U.S. Legal Claims Sequor Law represented a multinational Colombian food products company in recovering substantial losses for products obtained through fraud and deception. By deploying international treaties and U.S. domestic claims, the firm identified the products, prosecuted the defendants in the United States, and achieved a successful settlement. Representation of Peru in Kleptocracy Case Against Former Head of State Sequor Law represented the Government of Peru in litigation in Miami, Florida, where the plaintiff sought to attach the aircraft in which the President of Peru would travel to the United States. While asserting defenses under the Foreign Sovereign Immunities Act, including insufficient service of process, lack of personal jurisdiction, and failure to state a claim, the firm also argued that Peru was immune from attachment and suit. The court held that the aircraft was “military hardware” and therefore not subject to attachment. Representation of an Instrumentality of the French Government in Asset Recovery Matter Sequor Law represented Creances, S.A.S. (“CDR”), successor to Societe de Banque Occidentale (“SDBO”) and an instrumentality of the Republic of France, in a matter involving a nearly US$100 million fraudulent loan transaction that led to the sale of the collateral land without repayment. Sequor Law helped develop the strategy that ultimately led to the recovery of millions of dollars in real estate. Representation of the Government of Trinidad and Tobago in Bid-Rigging and Corruption Case Sequor Law represents the Republic of Trinidad and Tobago in related fraud and corruption proceedings in Florida, Liechtenstein, The Bahamas, Panama, and Switzerland. The matters involved coordination with governmental authorities, assistance with MLAT requests, and support for extradition proceedings. The work resulted in the freezing, recovery, and repatriation of more than US$5 million, settlements exceeding US$5 million, and savings of more than US$30 million through the invalidation of a fraudulent contract. Representation of Caribbean Central Bank in Insurance Industry Fraud Sequor Law represented the Republic of Trinidad and Tobago in designing the legal strategy for the recovery of assets for the Central Bank of Trinidad and Tobago in the CLICO insurance company corruption scandal. Corruption-Related Asset Recovery on Behalf of Antigua and Barbuda Sequor Law represented the Government of Antigua and Barbuda in a corruption matter spanning Florida, Bermuda, Hong Kong, Switzerland, the Isle of Man, and Cayman. The civil case resulted in the freezing, recovery, and repatriation of stolen assets, the repatriation of US$12 million to the client, and the cancellation of a fraudulent contract that saved the government more than US$20 million in future expenditures. Kleptocracy Case for the Republic of Haiti Sequor Law participated as part of a global team in advising the Republic of Haiti on aspects of Asset Recovery against the Duvalier regime. Advice to the International Commission Against Impunity in Guatemala Sequor Law participated as part of a global team in advising CICIG in connection with corruption claims and other wrongdoing involving the former president and administration in Guatemala. First Chapter 15 Cross-Border Insolvency Case in Florida Involving Central American Banking Group Sequor Law represents Bancafe International Bank (in Liquidation) (“BIB”). After the failure of Banco Cafeteros de Guatemala, BIB, a Barbados entity with extensive operations in Guatemala and assets in the United States, entered bankruptcy in Barbados. Acting for the custodian, PricewaterhouseCoopers, Sequor Law filed the first Chapter 15 case in Florida and obtained recognition of the Barbados liquidation as the main foreign proceeding. The matter has included extensive discovery in the United States and recoveries that include more than US$54 million from a REFCO bankruptcy claim and approximately US$1 million from a New York account. Chapter 15 Case Stemming from One of the Largest Banking Failures in Brazilian History Sequor Law represents the judicial administrator of Banco Santos, S.A. (in Liquidation). After an investigation revealed a theft of more than US$1 billion through a multi-country scheme, Sequor Law initiated a Chapter 15 proceeding. The corresponding recognition helped secure valuable evidence in the United States and elsewhere and supported the recovery of artwork valued in the millions, along with additional multi-million-dollar recoveries through a confidential ancillary settlement. Brazilian Cross-Border Insolvency Case with More Than 300 Related Debtors Sequor Law represents Petroforte Brasileiro de Petroleo Ltda. (“Petroforte”) (in Liquidation). After Petroforte entered insolvency proceedings in Brazil and the bankruptcy was extended to more than 300 entities and individuals, Sequor Law obtained deposition testimony and documentary evidence in the United States and pursued analogous proceedings in the Caribbean and Central America. The evidence supported the Judicial Administrator’s efforts in Brazil and may support additional recovery litigation, including through Chapter 15. Leading Appellate and Section 1782 Decisions Sequor Law prevailed before the Eleventh Circuit in Talal Qais Abdulmunem Al Zawawi v. Diss (In re Talal Qais Abdulmunem Al Zawawi), 97 F.4th 1244 (11th Cir. 2024), reinforcing the importance of Chapter 15 in cross-border cooperation. The firm has also helped shape the law under 28 U.S.C. § 1782, including In Application of Consorcio Ecuatoriano de Telecomunicaciones S.A. v. JAS Forwarding (USA), Inc., 747 F.3d 1262 (11th Cir. 2014), and Novalpina Cap. Partners I GP S.A.R.L. v. Read, 149 F.4th 1092 (9th Cir. 2025). Open Edward H. Davis, Jr. Founding Shareholder edavis@sequorlaw.com (+1) 305-372-8282, Ext. 228 Open Arnoldo B. Lacayo Shareholder alacayo@sequorlaw.com (+1) 305-372-8282, Ext. 230 Open Leyza B. Florin Shareholder lflorin@sequorlaw.com (+1) 305-372-8282, Ext. 300 Open Open Key contacts Key Contacts

Attorneys, forensic accountants, and investigators behind Sequor Law's global asset recovery and litigation practice. Board-certified specialists. Our Team Our team comprises multiple attorneys and professionals, bringing expertise across multiple practice areas. Please click the tabs below to explore our team by language, area of expertise, or office location. Reset All Filters Languages Spoken English Spanish Portuguese Chinese French Italian Show all Languages Practice Area Asset Recovery Bankruptcy & Insolvency Financial Fraud Bank Litigation International Commercial Litigation International Arbitration Judgment & Arbitral Award Enforcement High-Net-Worth Disputes Corruption & Proceeds of Crime Recovery Creditors' Rights Appellate Law Office Location Miami Washington D.C. Show all Offices Alain M. Acanda Attorney aacanda@sequorlaw.com (+1) 305-372-8282 vCard Alain M. Acanda Giovanni Angles Counsel gangles@sequorlaw.com (+1) 305-372-8282, Ext. 213 vCard Giovanni Angles Maria Jose Cortesi Attorney mcortesi@sequorlaw.com (+1) 305-372-8282, Ext. 265 vCard Maria Jose Cortesi Daniel M. Coyle Partner dcoyle@sequorlaw.com (+1) 305-372-8282, Ext. 244 vCard Daniel M. Coyle Edward H. Davis, Jr. Founding Shareholder edavis@sequorlaw.com (+1) 305-372-8282, Ext. 228 vCard Edward H. Davis, Jr. Andrew B. Dawson Of Counsel adawson@sequorlaw.com (+1) 305-372-8282, Ext. 269 vCard Andrew B. Dawson Leyza B. Florin Shareholder lflorin@sequorlaw.com (+1) 305-372-8282, Ext. 300 vCard Leyza B. Florin Gregory S. Grossman Founding Shareholder ggrossman@sequorlaw.com (+1) 305-372-8282, Ext. 235 vCard Gregory S. Grossman Michael Hanlon Attorney mhanlon@sequorlaw.com (+1) 305-372-8282 vCard Michael Hanlon Robert B. Kearney Attorney rkearney@sequorlaw.com (+1) 202-900-8739, Ext. 312 vCard Robert B. Kearney Arnoldo B. Lacayo Shareholder alacayo@sequorlaw.com (+1) 305-372-8282, Ext. 230 vCard Arnoldo B. Lacayo Bob Lindquist Director of Forensics blindquist@sequorlaw.com (+1) 305-372-8282 vCard Bob Lindquist Juan J. Mendoza Partner jmendoza@sequorlaw.com (+1) 305-372-8282, Ext. 250 vCard Juan J. Mendoza Fernando J. Menendez, Jr. Shareholder fmenendez@sequorlaw.com (+1) 305-372-8282, Ext. 299 vCard Fernando J. Menendez, Jr. Nyana Abreu Miller Partner nmiller@sequorlaw.com (+1) 305-372-8282, Ext. 296 vCard Nyana Abreu Miller Jennifer Mosquera Attorney jmosquera@sequorlaw.com (+1) 305-372-8282, Ext. 216 vCard Jennifer Mosquera William T. Nichols Director of Investigations wnichols@sequorlaw.com (+1) 305-372-8282 vCard William T. Nichols Christopher A. Noel Partner cnoel@sequorlaw.com (+1) 305-372-8282, Ext. 264 vCard Christopher A. Noel Tara J. Plochocki Partner tplochocki@sequorlaw.com (+1) 202-900-8740, Ext. 310 vCard Tara J. Plochocki Miguel E. Del Rivero Attorney mdrivero@sequorlaw.com (+1) 305-372-8282, Ext. 212 vCard Miguel E. Del Rivero Alejandro Rodriguez Vanzetti Attorney avanzetti@sequorlaw.com (+1) 305-372-8282, Ext. 233 vCard Alejandro Rodriguez Vanzetti Joseph B. Rome Partner jrome@sequorlaw.com (+1) 305-372-8282, Ext. 210 vCard Joseph B. Rome Noah Rosenblum Attorney nrosenblum@sequorlaw.com (+1) 305-372-8282 vCard Noah Rosenblum Carolina M. Rosso Attorney crosso@sequorlaw.com (+1) 305-372-8282 vCard Carolina M. Rosso David Short Counsel dshort@sequorlaw.com (+1) 202-900-8740 vCard David Short Filter Results

Led by two Chambers & Partners Band 1-ranked partners in Bankruptcy Litigation. Filed Florida's first Chapter 15. More Chapter 15 cases than any other firm. GRR 100 Bankruptcy & Insolvency Sequor Law represents clients in most aspects of bankruptcy and insolvency law both domestically and with insolvencies based outside the United States. The firm leverages unparalleled experience in connection with Chapter 15 of the Bankruptcy Code. Global Authority in Cross-Border Insolvency & Chapter 15 Practice Sequor Law provides comprehensive representation in all major aspects of bankruptcy and insolvency law, both in domestic and cross-border matters. In cross-border matters, the firm represents foreign-appointed fiduciaries responsible for the restructuring or liquidation of companies and individuals abroad. Sequor Law regularly appears in courts throughout the United States on behalf of foreign representatives. Having filed more Chapter 15 cases than any other firm , including the first Chapter 15 case ever filed in Florida, Sequor Law is consistently recognized as a leader in international insolvency and cross-border restructuring. Our attorneys frequently present at major conferences across North America, Latin America, Europe, and beyond on insolvency, Asset Recovery, and multi-jurisdictional enforcement. Sequor Law has been counsel in a substantial number of the Southern District of Florida’s reported Chapter 15 decisions, reinforcing its standing as one of the most experienced firms in cross-border insolvency nationwide. In In re Zawawi, the Eleventh Circuit held that 11 U.S.C. § 109 does not apply to Chapter 15, confirming that recognition is available even when a foreign debtor lacks residence, domicile, a place of business, or property in the United States. That decision is particularly significant because it ensures foreign representatives may obtain recognition and access essential discovery and enforcement tools without first establishing a U.S. nexus. The firm has handled Chapter 15 matters arising from jurisdictions including Antigua, Barbados, the British Virgin Islands, Canada, the Cayman Islands, the United Kingdom, Argentina, Austria, Brazil, Chile, Mexico, and Romania. Sequor Law has also served as lead counsel in recognition proceedings filed in foreign courts, including Australia, Colombia, the Isle of Man, Switzerland, and the United Kingdom. Precedent-Setting Litigation Shaping Cross-Border Insolvency Law In U.S. bankruptcy cases, Sequor Law represents creditors and other parties in interest across all phases of the proceeding. The firm regularly advocates for lenders in contested matters involving: Cash collateral disputes Valuation issues Motions for relief from the automatic stay and related defenses Plan treatment and confirmation challenges Competing reorganization plan proposals Sequor Law also defends clients in avoidance actions and represents creditors pursuing objections to dischargeability. Strategic Advocacy For Creditors In U.S. Bankruptcy Proceedings Representative Representative Cases One of the Largest Ponzi Schemes in History Sequor Law represents the Joint Liquidators for Stanford International Bank, Ltd. (“SIB”) (in Liquidation). SIB, a bank located in Antigua that primarily sold certificates of deposit, played a central role in a worldwide Ponzi scheme, the second largest in history, perpetrated by Robert Allen Stanford, with losses to depositors estimated to exceed US$4.4 billion. Since May 12, 2011, when Marcus Wide and Hugh Dickson of Grant Thornton were appointed Joint Liquidators of the SIB estate in Antigua, Sequor Law has acted as co-general counsel with Caribbean counsel in global Asset Recovery efforts that have included recovering US$3.2 million from Panama, US$20 million from the United Kingdom, freezing assets in Antigua & Barbuda valued at US$212 million, launching a formal claims process, pursuing claims related to approximately US$330 million in frozen assets in Canada, Switzerland, and the U.K., filing damages claims valued at approximately US$5 billion against a Canadian bank, and initiating recovery efforts in Colombia against law firms and financial institutions. Sequor Law also initiated a Chapter 15 recognition proceeding in Dallas, Texas, and later helped the U.S. Judicial Administrator, the SEC, the U.S. Department of Justice, the Joint Liquidators, and others reach a global agreement and cross-border protocol. First Chapter 15 Cross-Border Insolvency Case in Florida Involving Central American Banking Group Sequor Law represents Bancafe International Bank (in Liquidation) (“BIB”). After the failure of Banco Cafeteros de Guatemala, BIB, a Barbados entity with extensive operations in Guatemala and assets in the United States, entered bankruptcy in Barbados. Acting for the custodian, PricewaterhouseCoopers, Sequor Law filed the first Chapter 15 case in Florida and obtained recognition of the Barbados liquidation as the main foreign proceeding. The matter has included extensive discovery in the United States and recoveries that include more than US$54 million from a REFCO bankruptcy claim and approximately US$1 million from a New York account. Chapter 15 Case Stemming from One of the Largest Banking Failures in Brazilian History Sequor Law represents the judicial administrator of Banco Santos, S.A. (in Liquidation). After an investigation revealed a theft of more than US$1 billion through a multi-country scheme, Sequor Law initiated a Chapter 15 proceeding. The corresponding recognition helped secure valuable evidence in the United States and elsewhere and supported the recovery of artwork valued in the millions, along with additional multi-million-dollar recoveries through a confidential ancillary settlement. Brazilian Cross-Border Insolvency Case with More than 300 Related Debtors Sequor Law represents Petroforte Brasileiro de Petróleo Ltda. (“Petroforte”) (in Liquidation). After Petroforte entered insolvency proceedings in Brazil and the bankruptcy was extended to more than 300 entities and individuals, Sequor Law obtained deposition testimony and documentary evidence in the United States and pursued analogous proceedings in the Caribbean and Central America. The evidence supported the Judicial Administrator’s efforts in Brazil and may support additional recovery litigation, including through Chapter 15. Open Gregory S. Grossman Founding Shareholder ggrossman@sequorlaw.com (+1) 305-372-8282, Ext. 235 Open Leyza B. Florin Shareholder lflorin@sequorlaw.com (+1) 305-372-8282, Ext. 300 Open Fernando J. Menendez, Jr. Shareholder fmenendez@sequorlaw.com (+1) 305-372-8282, Ext. 299 Open Open Key contacts Key Contacts

Investor-state and commercial arbitration before ICC, ICDR, LCIA, ICSID, FINRA, and under UNCITRAL Rules. Most board-certified arbitration attorneys in Florida International Arbitration Sequor Law is deeply experienced as arbitration counsel in both investor-state and commercial arbitrations across a wide range of arbitral fora. Combined with its expertise in arbitral award collection, the firm is able not only to pursue favorable outcomes in arbitration, but also to position clients to collect on their awards. Sophisticated Dispute Resolution Across Jurisdictions, Languages, and Forums Sequor Law’s reputation is built on inventive strategic vision, meticulous preparation, and compelling advocacy, combined with comprehensive post-award evidence-gathering and recovery tools designed to secure enforcement. The firm’s International Arbitration experience includes investor-state and commercial disputes, particularly those connected to Latin America. Many of the substantive claims in these matters have little connection to the United States and are governed predominantly by foreign law. The team handles proceedings in English, Spanish, and Portuguese. Sequor Law has handled disputes in fora including the ICC, AAA-ICDR, LCIA, ICSID, FINRA, and ad hoc arbitrations under the UNCITRAL Rules. Having navigated disputes caused by poorly drafted arbitration clauses, Sequor Law also advises clients on drafting effective arbitration provisions for business transactions. The firm’s attorneys regularly lecture on arbitral clause drafting and strategy. Arbitration often gives rise to parallel litigation, whether to compel arbitration, resist efforts to circumvent arbitration agreements, or confirm or vacate awards. Sequor Law has litigated each of these issues and coordinates with trusted foreign counsel to craft a global strategy. Coordinated Global Strategy Across Arbitration and Parallel Proceedings The Benchmark for Board-Certified International Arbitration Excellence Sequor Law’s lawyers are recognized leaders in the field. Giovanni Angles serves on the Board of Directors of the Miami International Arbitration Society and is a past President of AIJA’s International Arbitration Commission. Alain Acanda serves on the leadership team of Young MIAS and chairs a committee within The Florida Bar’s International Law Section. Founding Shareholder Edward H. Davis, Jr. chaired The Florida Bar’s International Litigation and Arbitration Committee. Davis, together with Gregory S. Grossman, Arnoldo B. Lacayo, and Leyza B. Florin, are board certified in International Litigation and Arbitration by The Florida Bar, the highest number of certified attorneys in this practice area among Florida firms. Representative Representative Cases Shareholder Dispute Over Debt Enforcement, Share Valuation, and Post-Award Remedies Sequor Law served as counsel to the 50% owner of a Guatemalan telecom company in a multimillion-dollar shareholder dispute involving debt enforcement and share valuation. The matter proceeded before a single arbitrator under ICDR rules and also involved a court-issued injunction against arbitrating with non-signatories and judicial post-award remedies for non-monetary relief. Multimillion-Dollar Dispute Involving Cruise Ship Lease and Tortious Interference Sequor Law served as counsel for a casino cruise ship operator in a dispute against the vessel owner-lessor involving breach of lease, frustration of purpose, and tortious interference with contract. The matter proceeded before a three-member ad hoc arbitration panel and also included court litigation over the designated arbitral forum. Open Giovanni Angles Counsel gangles@sequorlaw.com (+1) 305-372-8282, Ext. 213 Open Joseph B. Rome Partner jrome@sequorlaw.com (+1) 305-372-8282, Ext. 210 Open Edward H. Davis, Jr. Founding Shareholder edavis@sequorlaw.com (+1) 305-372-8282, Ext. 228 Open Open Key contacts Key Contacts

Asset recovery, financial fraud, international arbitration, bankruptcy, cross-border insolvency, and judgment & arbitral award enforcement. Serving clients worldwide Practice Areas Attacking fraud and corruption from every angle, we cross the boundaries of practice areas from investigation to litigation, arbitration, and asset recovery. Asset Recovery Announcement Bankruptcy & Insolvency Announcement Financial Fraud Announcement Bank Litigation Announcement International Commercial Litigation Announcement International Arbitration Announcement Judgment & Arbitral Award Enforcement Announcement High-Net-Worth Disputes Announcement Corruption & Proceeds of Crime Recovery Announcement Creditors' Rights Announcement Appellate Law Complementary Resources Our forensic accounting team deploys innovative investigation techniques to support complex cases. We also collaborate with leading litigation funders to power our clients' cases through litigation to collection. Announcement Investigations Announcement Forensic Accounting Evidence Gathering Tools Announcement Alternative Fee Arrangements & Litigation Funding Support Legal Prowess. Global Impact.

Tracing concealed and undervalued assets in high-net-worth matrimonial and commercial disputes. Forensic accounting, global investigators, and litigation funding support. High-Net-Worth Disputes The Sequor Law team is equipped with sophisticated investigative tools and access to a global network of investigators, accountants, and international lawyers experienced in identifying assets that were not disclosed or were grossly undervalued in matrimonial, inheritance, and other family matters. Sequor Law not only finds these assets, but works to recover concealed personal wealth for its clients. Recovering What Was Hidden: Complex Asset Tracing in High-Net-Worth Disputes High-net-worth individuals often hide assets from their spouses, particularly when anticipating divorce. Similarly, family members in control of inherited property may seek to hide it from rightful heirs. These assets are frequently placed in complex corporate structures, offshore holdings, trusts, and similar vehicles designed to keep them out of reach. Where an aggrieved spouse or heir has been left with litigation fatigue and limited resources to fund recovery efforts, Sequor Law works closely with litigation funders experienced in identifying and financing matters with strong recovery potential. Experienced family law attorneys understand that asset disclosure fraud is common in high-net-worth divorce matters. That is why Board-Certified Marital and Family Law attorneys, members of the International Academy of Family Lawyers, and members of the American College of Trial Lawyers frequently co-counsel with and refer asset investigation and recovery matters to Sequor Law. Open Edward H. Davis, Jr. Founding Shareholder edavis@sequorlaw.com (+1) 305-372-8282, Ext. 228 Open Leyza B. Florin Shareholder lflorin@sequorlaw.com (+1) 305-372-8282, Ext. 300 Open Christopher A. Noel Partner cnoel@sequorlaw.com (+1) 305-372-8282, Ext. 264 Open Open Key contacts Key Contacts

Led by a former ICC FraudNet Executive Director. Multi-jurisdictional fraud investigations and asset recovery across the Caribbean, Latin America, and Europe Financial Fraud Sequor Law frequently coordinates multi-jurisdictional investigations and asset recovery efforts with legal, forensic and investigative experts in the United States and other global jurisdictions, leveraging our leadership in the International Chamber of Commerce’s (ICC) FraudNet. Strategic Legal Responses to Complex Financial Fraud Schemes Individuals, businesses, institutions, governments, and government instrumentalities are victimized by financial fraud every day. The losses are staggering, and the effects are often devastating. No one, regardless of sophistication, is fully immune. When faced with financial fraud, victims must decide whether to act to redress the harm and hold the fraudster and the fraudster’s facilitators accountable. Inaction benefits only the wrongdoer and makes the loss permanent. Sequor Law has built a financial fraud practice focused on helping victims investigate misconduct and pursue effective legal strategies and claims against fraudsters of every kind. Sequor Law’s financial fraud team frequently leads and coordinates multi-jurisdictional investigations and asset recovery efforts with legal, forensic, and investigative professionals across the Caribbean, Central and South America, Canada, Europe, and Asia. With expertise in finance and accounting and fluency in multiple languages, the team analyzes global evidence in real time and drives cases forward as quickly and cost-effectively as possible. The firm also maintains tested relationships with third-party litigation funders that can help victims prosecute financial fraud claims against well-funded adversaries. Real-Time Global Intelligence Across Languages and Legal Systems Rapid Global Deployment Through the World's Premier Fraud Network Sequor Law leverages its leadership role in the ICC’s FraudNet, the premier financial fraud and asset recovery network in the world. Through this network, whether the fraud’s nexus and the ultimate destination of misappropriated assets are in the United States or elsewhere, the firm can mobilize a truly global response. Representative Representative Cases One of the Largest Ponzi Schemes in History Sequor Law represents the Joint Liquidators for Stanford International Bank, Ltd. (“SIB”) (in Liquidation). SIB, a bank located in Antigua that primarily sold certificates of deposit, played a central role in a worldwide Ponzi scheme, the second largest in history, perpetrated by Robert Allen Stanford, with losses to depositors estimated to exceed US$4.4 billion. Since May 12, 2011, when Marcus Wide and Hugh Dickson of Grant Thornton were appointed Joint Liquidators of the SIB estate in Antigua, Sequor Law has acted as co-general counsel with Caribbean counsel in global Asset Recovery efforts that have included recovering US$3.2 million from Panama, US$20 million from the United Kingdom, freezing assets in Antigua & Barbuda valued at US$212 million, launching a formal claims process, pursuing claims related to approximately US$330 million in frozen assets in Canada, Switzerland, and the U.K., filing damages claims valued at approximately US$5 billion against a Canadian bank, and initiating recovery efforts in Colombia against law firms and financial institutions. Sequor Law also initiated a Chapter 15 recognition proceeding in Dallas, Texas, and later helped the U.S. Judicial Administrator, the SEC, the U.S. Department of Justice, the Joint Liquidators, and others reach a global agreement and cross-border protocol. Representation of a Class of More Than 2,000 Victims of Caribbean Fraud Sequor Law represented a class of 2,232 victims of the Leadenhall Bank & Trust and Cash-4-Titles fraud in the British Virgin Islands and The Bahamas and recovered US$14.4 million. After Leadenhall entered liquidation and was sued in the U.S. District Court in Miami, the class obtained a final money Judgment of US$313 million in September 2007. Enforcement of that Judgment resulted in the US$14.4 million recovery, with approximately US$7 million more to be distributed thereafter. Deployment of International Treaties and U.S. Legal Claims Sequor Law represented a multinational Colombian food products company in recovering substantial losses for products obtained through fraud and deception. By deploying international treaties and U.S. domestic claims, the firm identified the products, prosecuted the defendants in the United States, and achieved a successful settlement. Representation of Instrumentality of the French Government in Asset Recovery Matter Sequor Law represented Créances, S.A.S. (“CDR”), successor to Société de Banque Occidentale (“SDBO”) and an instrumentality of the Republic of France, in a matter involving a nearly US$100 million fraudulent loan transaction that led to the sale of the collateral land without repayment. Sequor Law helped develop the strategy that ultimately led to the recovery of millions of dollars in real estate. Representation of Caribbean Central Bank in Insurance Industry Fraud Sequor Law represented the Republic of Trinidad and Tobago in designing the legal strategy for the recovery of assets for the Central Bank of Trinidad and Tobago in the CLICO insurance company corruption scandal. First Chapter 15 Cross-Border Insolvency Case in Florida Involving Central American Banking Group Sequor Law represents Bancafe International Bank (in Liquidation) (“BIB”). After the failure of Banco Cafeteros de Guatemala, BIB, a Barbados entity with extensive operations in Guatemala and assets in the United States, entered bankruptcy in Barbados. Acting for the custodian, PricewaterhouseCoopers, Sequor Law filed the first Chapter 15 case in Florida and obtained recognition of the Barbados liquidation as the main foreign proceeding. The matter has included extensive discovery in the United States and recoveries that include more than US$54 million from a REFCO bankruptcy claim and approximately US$1 million from a New York account. Chapter 15 Case Stemming from One of the Largest Banking Failures in Brazilian History Sequor Law represents the judicial administrator of Banco Santos, S.A. (in Liquidation). After an investigation revealed a theft of more than US$1 billion through a multi-country scheme, Sequor Law initiated a Chapter 15 proceeding. The corresponding recognition helped secure valuable evidence in the United States and elsewhere and supported the recovery of artwork valued in the millions, along with additional multi-million-dollar recoveries through a confidential ancillary settlement. Brazilian Cross-Border Insolvency Case with More Than 300 Related Debtors Sequor Law represents Petroforte Brasileiro de Petroleo Ltda. (“Petroforte”) (in Liquidation). After Petroforte entered insolvency proceedings in Brazil and the bankruptcy was extended to more than 300 entities and individuals, Sequor Law obtained deposition testimony and documentary evidence in the United States and pursued analogous proceedings in the Caribbean and Central America. The evidence supported the Judicial Administrator’s efforts in Brazil and may support additional recovery litigation, including through Chapter 15. Open Edward H. Davis, Jr. Founding Shareholder edavis@sequorlaw.com (+1) 305-372-8282, Ext. 228 Open Arnoldo B. Lacayo Shareholder alacayo@sequorlaw.com (+1) 305-372-8282, Ext. 230 Open Leyza B. Florin Shareholder lflorin@sequorlaw.com (+1) 305-372-8282, Ext. 300 Open Open Key contacts Key Contacts

Enforcing large judgments and arbitral awards for Fortune 500 companies, global banks, and sovereigns. Pursuing nominees, alter egos, and facilitators of concealment Judgment & Arbitral Award Enforcement Sequor Law represents Fortune 50 companies, global banks, large foreign corporations, and government entities in judgment and arbitral award collection matters. Decades of Experience Enforcing Complex Judgments & Awards Worldwide Sequor Law has decades of experience enforcing large judgments and arbitral awards rendered in the United States and abroad, including against large corporations and sovereigns. The firm represents Fortune 500 companies, global banks, major foreign corporations, and government entities in judgment and arbitral award collection matters. Sequor Law uses cash-flow analysis and asset tracing methods to expose concealed assets. The firm has substantial experience in post-judgment evidence gathering and recovery methods, including garnishments, freeze orders, sequestration orders, and writs of execution. In addition to identifying debtor assets, Sequor Law vigorously pursues nominees, alter egos, and others who improperly received money or property from the debtor. Where accountants, attorneys, or other asset protection specialists participate in concealment schemes, Sequor Law pursues conspiracy and aiding-and-abetting claims against those facilitators. Post-judgment and post-award enforcement has become a highly sophisticated and specialized practice, which is why leading litigators and litigation funders in the United States and abroad refer hard-earned judgments to Sequor Law for enforcement. Tracing Assets, Piercing Schemes, & Pursuing Every Responsible Party Representative Representative Cases Representation of Decedent’s Estate in Judgment Collection Sequor Law represented the personal representative of a decedent’s estate in a New York probate matter enforcing a high-value judgment against a family member who misappropriated estate assets and misused a limited power of attorney. The matter began with domestication of the New York judgment under the Florida Enforcement of Foreign Judgments Act. Brazilian Judgment Holder in Recognition and Enforcement of Foreign Judgment Sequor Law represented the holder of a high-value Brazilian Judgment in obtaining recognition under Florida’s Uniform Out-of-Country Money Judgment Act, defeating arguments that the Brazilian orders were not final because they arose from a homologated settlement. The case included depositions and trial testimony from Brazilian law experts. Defense of Regional Bank Against Customer Claims Regarding PPP Loans Sequor Law successfully defended Ocean Bank against allegations that the bank failed to properly administer PPP loan processes in connection with a forgiveness request. Defense of Regional Bank Against Assignee Regarding Overdraft Fees Sequor Law successfully defended Ocean Bank against allegations by an assignee in an assignment for the benefit of creditors that the bank improperly assessed overdraft fees and charges. Representation of Barclays Bank in Letter of Credit Dispute Sequor Law obtained summary Judgment establishing that, under UCC Article 5 and applicable law, a letter of credit issuer had no preferred rights to proceeds paid under the letter of credit. Open Edward H. Davis, Jr. Founding Shareholder edavis@sequorlaw.com (+1) 305-372-8282, Ext. 228 Open Leyza B. Florin Shareholder lflorin@sequorlaw.com (+1) 305-372-8282, Ext. 300 Open Tara J. Plochocki Partner tplochocki@sequorlaw.com (+1) 202-900-8740, Ext. 310 Open Open Key contacts Key Contacts

Explore how the 9th Circuit's decision impacts the Foreign Discovery Statute. Learn about the expansive use of the Foreign Discovery Statute. 9th Circuit Greenlights Expansive Use of Discovery Statute, Law360, Aug. 13, 2025 Open In the News Open August 13, 2025 1 minute read Sequor Law Open the full article here Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Rolling Stone’s 2018 feature on the ‘kill list’ case put Tara J. Plochocki’s fight for a citizen’s due process rights before a national audience. How to Survive America’s Kill List Open In the News Open July 19, 2018 2 minutes read Sequor Law When *Rolling Stone* gave a single federal lawsuit the full weight of a long-form investigative feature, it made a quiet argument: the question of whether a citizen can be killed without a hearing belongs to the public, not only to lawyers and judges working behind closed doors. The 2018 piece followed Bilal Abdul Kareem, an American journalist who came to believe his work in Syria had landed him on a secret government targeting list after he survived a series of airstrikes. What might have read as a personal survival story instead opened onto a constitutional question most Americans never face: whether a citizen can even find out that his government has marked him for a drone strike, and whether a court is allowed to review that decision at all. For the press, these are not abstract concerns. Kareem was reporting from a war zone, and the case raised the prospect that journalists doing dangerous, unpopular work could be swept into a lethal designation with no way to contest it. Press freedom and due process rights, usually treated as separate concerns, met in a single file. A magazine known for cultural reporting recognized that and gave it the length the subject demanded, reaching readers who would never open a national security law journal. Carrying that litigation was attorney Tara J. Plochocki , who represented Kareem alongside the human rights organization Reprieve. The matter produced a notable result: a federal judge allowed his due process claim to move forward, refusing to treat the government's targeted killing authority as entirely beyond judicial review. For a citizen who wanted nothing more than a chance to be heard before the use of lethal force, that ruling mattered. The feature is worth reading in full for how it turns a dense legal fight into human terms. Sequor Law points readers to the original reporting: "How to Survive America's Kill List." The case also says something about the kind of work that defines Plochocki's record. She took it on earlier in her career; today she is a Partner at Sequor Law, where she leads the firm's Washington, D.C. office. An ICC FraudNet member admitted to the U.S. Supreme Court and the D.C. and Second Circuits, she built a practice around cross-border asset recovery, financial fraud, and international commercial litigation, and she still litigates at the intersection of constitutional rights, international law, and national security, including amicus briefs on the laws of war. Beyond one man's ordeal, the feature kept a single premise in view: that government power, however secret, still answers to the Constitution — a kill list included. Testing that in court, and a national publication taking the time to explain why it counts, kept a hard question from slipping out of public view. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

Sequor Law's Leyza B. Florin, Andrew Dawson, and Greg Grossman examine how Florida's bankruptcy courts have become leaders in Chapter 15 asset recovery, published in Asset Recovery Magazine. Asset Recovery Magazine – Florida Leads the Way in Development of Chapter 15 Jurisprudence Open Legal Insights Open August 30, 2019 9 minutes read Sequor Law By Leyza B. Florin , Andrew B. Dawson and Greg S. Grossman Chapter 15 of the Bankruptcy Code has become a powerful asset recovery tool, and the Florida bankruptcy courts have been leading the way in this development. The Southern District of Florida has seen more Chapter 15 lings than any court other than the Southern District of New York, and many of these Florida Chapter 15 cases have been focused on assisting foreign trustees and liquidators track down and recover assets in the United States. Our team at Sequor Law in Miami has alone led over forty chapter 15 cases. While Chapter 15 is not a new tool—it is approaching its fourteenth birthday—it is, like many a teenager, under-appreciated and at times misunderstood. This is in part because Chapter 15 is not really “bankruptcy” in the sense that it does not create a bankruptcy estate or appoint a trustee. Instead, Chapter 15 provides a procedure to assist trustees administer foreign insolvency cases whose cross- border estates reach into the United States. The underappreciation also stems in part because Chapter 15’s substantive contours remain unknown, as it is primarily a procedural vehicle with minimal substantive constraints. Finally, because Chapter 15 requires U.S. bankruptcy courts to interface with foreign insolvency proceedings, there has been a great deal of uncertainty as to how open courts would be to cooperating with foreign insolvency proceedings, particularly when those foreign proceedings involve insolvency laws that are importantly different from U.S. bankruptcy law in substance and process. One common concern when Chapter 15 was rst enacted in 2008 was that U.S. bankruptcy courts might be reluctant to cooperate with foreign proceedings—or that they would cooperate inconsistently—in the face of foreign insolvency laws. Florida bankruptcy courts have in recent years played a key role in the development of Chapter 15. It is perhaps no surprise that courts here have been leaders in this arena, particularly as to cross-border insolvencies originating from Latin and South America. These courts have played important roles in establishing precedent for inter- American cooperation and assistance in this still-developing area of law. This article will discuss three recent decisions that highlight developments that may be of particular interest in asset recovery efforts. Chapter 15: A Bankruptcy without a Bankruptcy Estate Chapter 15 of the U.S. Bankruptcy Code provides a powerful tool kit for bankruptcy trustees and liquidators, but it is not itself a “bankruptcy” case. It does not open a full bankruptcy proceeding or create an estate, as would happen in a typical corporate bankruptcy case. Instead, Chapter 15 creates a process to assist the representative of a foreign proceeding, whether that be a debtor- in-possession, trustee, monitor, or other official. Chapter 15 permits that foreign representative to open a case in the bankruptcy court in order to seek assistance within the United States, with that assistance ranging from discovery orders to asset turnover orders. The bankruptcy court’s threshold function is to determine whether to recognize foreign proceeding, either a foreign main proceeding (i.e., one led where the debtor has its “center of main interests”) or foreign nonmain proceeding (i.e., one led where the debtor has an establishment). The court then has discretion to fashion assistance. Thus, there is no actual “debtor” in the Chapter 15 case and no estate is created. Whereas a traditional bankruptcy case can be a cost-intensive and disruptive endeavor—trustees are appointed, claims must be processed, assets liquidated and distributed, etc. —Chapter 15, in contrast, is not a traditional bankruptcy case. Rather, it is an ancillary case in aid of the foreign bankruptcy proceeding. It is thus more exible and less onerous than a traditional bankruptcy case. The main questions in these ancillary cases concern what aid is available to the trustees of the foreign insolvency cases. Chapter 15 provides some very speci c procedures designed to facilitate that cross-border assistance, e.g., authorizing judge-to-judge communications, and it provides a non-exclusive list of relief the U.S. bankruptcy court can grant to the foreign representative. As with any relatively new legislation, there is a lot of uncertainty as to the extent of that relief and to the standards for granting that relief. The uncertainty in Chapter 15 has an additional complicating factor due to its cross-border nature: would U.S. bankruptcy courts extend relief to foreign bankruptcy proceedings that differ from U.S. bankruptcy law and procedures? Three Florida cases brought by Sequor Law on behalf of foreign representatives, illustrate these issues and show how the Florida bankruptcy courts have helped fashion answers and standards. Who is the Foreign “Debtor”: In re Petroforte The first case is by now well known in the cross-border insolvency world so will receive only a cursory treatment; however, it would be remiss to exclude the case altogether as it has had important rami cations throughout the Chapter 15 jurisprudence. Petroforte was one of Brazil’s largest gas and ethanol distributors before entering bankruptcy. That liquidation had uncovered evidence of fraudulent transfers made to several entities, which provided the basis for the Brazilian court to enter ex parte an order extending the bankruptcy case to include the transferees. The Brazilian trustees commenced a Chapter 15 proceeding in the Southern District of Florida to seek discovery to assist the Brazilian liquidation. Some of these discovery targets objected on two main grounds: first, the argued that the Chapter 15 court should refuse to recognize the Brazilian extension order on public policy grounds; second, they argued that the foreign representative could not use Chapter 15 to order discovery against the transferees because they were not “debtors”. In what is now a widely-cited case (In re Petroforte Brasileiro de Petroleo Ltda. , 542 B.R. 899 (Bankr. S.D. Fla. 2015)), Judge Robert Mark rejected the first argument. He noted that U.S. courts grant a similar type of relief under the equitable remedy of substantive consolidation, and thus the Brazilian extension order was not substantively offensive as a matter of public policy. As to the ex parte nature of the proceedings, he acknowledged that this differs from U.S. procedure, which would have provided the remedy of substantive consolidation only upon an open hearing; however, he noted that the parties had the opportunity to be heard at the appellate level in Brazil. Consequently, the Brazilian proceeding did not offend U.S. public policy. As to the scope of discovery assistance under Chapter 15, the court had to interpret the scope of “debtor” under section 1521(a)(4), which provides that a court may authorize the “the examination of witnesses, the taking of evidence or the delivery of information concerning the debtor’s assets, affairs, rights, obligations or liabilities.” Judge Mark held that the entities that were subject to the Brazilian extension order were “debtors” subject to section 1521’s discovery powers. As to third parties who were not subject to the Brazilian extension order, the bankruptcy court in Petroforte held the trustee may be entitled to broad discovery to the extent the debtor is a majority stockholder in the non-debtor discovery target. Such broad discovery “allows the Trustee to determine whether the stock, which is an asset of the estate, has sufficient value to induce the Trustee to take control of the entity, and attempt to derive value by selling or liquidating the entity.” Broad Discovery Relief: In re SAM Industrias, S.A. In re SAM Industrias, S.A ., 2019 WL 1012790 (Bankr. S.D. Fla. March 1, 2019), built upon the foundation laid in Petroforte. In Petroforte, Judge Mark also suggested an alternative basis for ordering broad investigation into third party transactions in situations in which the third parties were actually involved in the fraudulent transfer or had otherwise engaged in wrongdoing: “The Trustee’s Supplemental Response failed to establish any actual involvement in the Plant Transaction or any wrongdoing by any of the Third Party Targets.” The court, though, did not further discuss this alternative ground. The issue arose in SAM Industrias when the foreign representative of the Brazilian liquidation led a Chapter 15 in the Southern District of Florida to investigate potential fraudulent transferees identified by the Brazilian courts. The Brazilian courts had found that the debtor had undisclosed interests in certain corporate entities, which he had concealed by transferring to family members. The foreign representative, accordingly, sought the Chapter 15 court’s assistance in examining these family members, who were not themselves debtors in Brazil, and in examining certain non-debtor corporate entities. The debtor objected to this assistance, arguing that the requested discovery assistance falls outside the scope of Chapter 15’s relief because the discovery targets were not debtors in Brazil. As to the family members, the Chapter 15 court examined the Brazilian court record carefully and concluded that discovery was appropriate as to those family members identified as transferees of the debtor’s property. The foreign representative, accordingly, was entitled to discover information related to the transferees’ corporate and financial affairs. As to the non-debtor corporate entities, the foreign representative was entitled to broad discovery not only as to those entities in which the debtor had a majority interest but also in those entities found to have participated in the debtor’s asset concealment scheme. Again, in defining the scope of relief available to the foreign representative, the Chapter 15 court examined the findings of the Brazilian courts. The Brazilian courts had found that the debtor had concealed assets through certain corporate pass- throughs owned and controlled by the debtor. The foreign representative was thus entitled to discovery related to these corporate pass-throughs. The foreign representative, though, was not entitled to discovery related to the non-debtor entities whose connections to the debtor had not yet been established in the Brazilian courts. Accordingly, the court concluded that the foreign representative is not entitled to “carte-blanche in his inquiries of non-debtors,” but that he is entitled to obtain information narrowly tailored “to discover ‘the legal entities created in purely fictional form’ which are part of a ‘complex corporate structure’ obscuring” the debtor’s ownership of corporate assets. The Foreign Revenue Rule: In re Dixon In re Dixon (Case No. 16-bk-02453, M.D. Fla. March 23, 2016) illustrates Chapter 15’s exibility, as it required the court to consider a novel application of the Foreign Revenue Rule to a Canadian trustee’s request for assistance. The Canadian debtors commenced proceedings in Canada under the Bankruptcy and Insolvency Act. The foreign representative subsequently led a Chapter 15 proceeding in the Middle District of Florida, seeking discovery assistance related to the debtor’s assets in the United States. When the foreign representative sought authorization to sell the debtors’ U.S. property in aid of the Canadian liquidation, the debtors led their own bankruptcy case under Chapter 13 of the Bankruptcy Code and later sought to dismiss the Chapter 15 proceedings. They argued that the Chapter 15 petition would violate the Foreign Revenue Rule. The Foreign Revenue Rule is “a long- standing common law rule that prevents the courts of one sovereign from enforcing or adjudicating tax claims from another sovereign.” Here, the debtors’ principal obligations were unpaid tax debts owed in Canada. Republic of Honduras vs. Philip Morris Companies, Inc., 341 F.3d 1253, 1260 (11th Cir. 2003). The issue, as urged by the debtors, was whether a Chapter 15 court could order to liquidate U.S. property for the purpose of satisfying Canadian tax claims. Judge Caryl Delano noted that the application of the Foreign Revenue Rule in the Chapter 15 context was a matter of first impression. Traditionally, in non- chapter 15 contexts, courts would refuse to permit a U.S. proceeding (whether in bankruptcy or not) to adjudicate tax claims under foreign laws. Section 1513(b)(2)(A) states that the language in subsection (a) and paragraph (1) “do not change or codify present law as to the allowability of foreign revenue claims or other foreign public law claims in a proceeding under this title.” Section 1513(b)(2)(B) goes on to say “[a]llowance and priority as to a foreign tax claim or other foreign public law shall be governed by any applicable tax treaty of the United States, under the conditions and circumstances specified therein.” The bankruptcy court ruled that the Revenue Rule did not apply because it was not being asked to “adjudicate or rule upon the validity or priority of the Canadian taxing authorities’ claims.” That matter, the court noted, would have to be decided in the Canadian proceeding. Second, the court noted that as a general matter, Chapter 15 courts are not in the business of adjudicating the validity of foreign claims. Finally, the court held that the case did not touch on any fundamental U.S. public policies, as it was simply a dispute as between the debtors and the foreign representative. In fact, the court found that it was promoting the public policies underlying not only Chapter 15 but the U.S.-Canada tax treaty. As an aside, the court noted that, to the extent the Canadian case involved more than just tax claims, that would further support its conclusion that the Foreign Revenue Rule does not apply. Conclusion These three Florida case descriptions illustrate how Chapter 15 of the Bankruptcy Code has elements of both bankruptcy law and more traditional asset recovery tools. When considering whether Chapter 15’s toolbox could help in the asset recovery effort, it appears the sun is shining in Florida’s bankruptcy courts. Click here to read the full article. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.

A Florida court grants Chapter 15 recognition to BVI liquidators of three 1MDB-linked funds. Sequor Law's Juan Mendoza represents the liquidators seeking US discovery to recover stolen assets. Liquidators of BVI Funds Linked to 1MDB Win Recognition in Florida Open In the News Open May 18, 2022 4 minutes read Sequor Law Ben Clarke 18 May, 2022 The joint liquidators of three 1MDB-linked British Virgin Islands funds have secured recognition of their appointments in Miami, pledging to obtain discovery in the US to help with their recovery efforts. In an oral ruling on 18 May, Judge Robert Mark in the US Bankruptcy Court for the Southern District of Florida recognized the BVI liquidations of SRC International (Malaysia) (SRC BVI) and subsidiaries SRC Strategic Resources and Bright Oriande. The judge also granted a motion to jointly administer the proceedings. While Judge Mark agreed to recognize the liquidators’ appointments, he questioned the draft order provided – particularly a clause that would have blocked any party from bringing a claim against the joint liquidators in any US court without first obtaining leave of the bankruptcy court. Counsel to the liquidators, Sequor Law’s Juan Mendoza , said the clause was included to enforce the Barton doctrine, established by the Supreme Court to require any party wishing to bring a claim against a receiver to first obtain the leave of the court that appointed the receiver. He said the clause was actually “Barton-lite” because they were not requesting potential litigants gain approval from the BVI courts to launch an action against the joint liquidators in the US. The judge said he would take the clause out but would include it in an amended order if he is provided with the relevant authorities. He said he didn’t fault the purpose or intent of the clause, to prevent the potential harassment of the joint liquidators, but he considered it “pretty sweeping relief” that pre-empts unknown future events. Fraud scheme The rulings come after the joint liquidators, BVI-based Helen Janes of Hyperion Risk Solutions and Quantuma’s Angela Barkhouse in the Cayman Islands and Carl Jackson in the UK, filed Chapter 15 proceedings last month in an effort to recover some of the billions of dollars allegedly stolen from Malaysian sovereign wealth fund 1MDB. Various authorities around the world have been investigating 1MDB and an entity it established in Malaysia, SRC International (SRC Malaysia), for the last seven years over a huge fraud that saw about US$8.5 billion diverted from them to numerous entities and individuals. During the short recognition hearing, Mendoza highlighted some of the suspicious transactions the joint liquidators have identified involving the three debtor companies – including over US$1 billion of funds transferred from SRC Malaysia to SRC BVI bank accounts in Hong Kong and Switzerland, and about US$60 million transferred to SRC Strategic Resources. Mendoza noted SRC BVI invested almost US$250 million into three funds of segregated portfolio company Asia Momentum Fund, which only ended up with a balance of about US$17 million. He also highlighted about US$652 million of investments in two BVI companies between 2011 and 2014, which he said “basically evaporated” as a result of redemptions that left no trace. Janes said in court filings last month that most investigation attempts in Malaysia were thwarted by the Malaysian government because the country’s Prime Minister, Najib Razak, was the force behind the creation of 1MDB. But Najib was removed from office in 2018 and has faced criminal and civil proceedings with other co-conspirators in relation to the misappropriation of 1MDB funds. While the US Department of Justice has also investigated multiple parties, and last month secured a conviction against former Goldman Sachs banker Roger Ng for his role in the scandal, Janes said it has focused its efforts on 1MDB and not SRC Malaysia, the parent of the three BVI funds. The joint liquidators have issued proceedings against companies in multiple jurisdictions since they were appointed last Summer, but Janes said they suspect there are other entities related to the fraud that are yet to be uncovered. According to Janes, SRC BVI has been principally used by fraudsters throughout its existence to misappropriate funds, and Bright Oriande is believed to have been established solely to divert funds from 1MDB and SRC Malaysia. With recognition of their appointments, the joint liquidators intend to obtain discovery relating to transactions involving the debtors so they can take steps to potentially realize assets for creditors. In the US Bankruptcy Court for the Southern District of Florida Judge Robert Mark Foreign representatives of SRC International (Malaysia) et al Hyperion Risk Solutions Group head of finance Helen Janes in the British Virgin Islands Quantuma Caribbean head Angela Barkhouse in the Cayman Islands and chief executive Carl Jackson in Southampton, UK Counsel to joint liquidators of SRC International (Malaysia) et al Sequor Law Shareholder Gregory Grossman and attorneys Juan Mendoza and Jennifer Mosquera in Miami In the British Virgin Islands Commercial Division Joint liquidators of SRC International (Malaysia) et alJoint liquidators of SRC International (Malaysia) et al Hyperion Risk Solutions Group head of finance Helen Janes in the British Virgin Islands Quantuma Caribbean head Angela Barkhouse in the Cayman Islands and chief executive Carl Jackson in Southampton, UK Counsel to joint liquidators of SRC International (Malaysia) et alCounsel to joint liquidators of SRC International (Malaysia) et al Emery Cooke Partner Andrew Emery in the British Virgin Islands To read the original article click here . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight May 19, 2026 1 minute read Attorney Spotlight – Get to Know Noah Rosenblum 1. What inspired you to pursue a law career? I was drawn to law because I've always enjoyed solving complicated problems and thinking.. Attorney Spotlight May 9, 2026 2 minutes read Attorney Spotlight – Get to Know Michael Hanlon 1. What inspired you to pursue a law career? I was less drawn to law in the abstract and more.. Firm News Apr 11, 2026 2 minutes read Sequor Law Celebrates National Pet Day with Continued Support of Paws4You Rescue In recognition of National Pet Day, Sequor Law is proud to continue its support of Paws4You Rescue, a Miami-based nonprofit... Attorney Spotlight Jan 29, 2026 2 minutes read Attorney Spotlight – Get to Know Alain M. Acanda 1. What inspired you to pursue a law career? I was inspired to pursue a career in the law after having negative experiences with the law as.