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Sequor Law attorneys Christopher A. Noel and Templeton N. Timothy examine recent legislation criminalizing the demand-side of international bribery and extortion in The Florida Bar's International Law Quarterly. Sequor’s Insights on International Anti-Bribery Legislation Open Legal Insights Open September 30, 2024 1 minute read Sequor Law Read Christopher A. Noel and Templeton N. Timothy’s article for The Florida Bar’s International Law Quarterly that examines recent legislation that criminalizes the demand-side of international bribery and extortion. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. 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..

Sequor Law Founding Shareholder Gregory Grossman spoke at IBRA – Instituto Brasileiro de Rastreamento de Ativos, addressing asset tracing and recovery professionals. Gregory Grossman Spoke at Ibra- Instituto Brasileiro de Rastreamento de Ativos Open Events & Speaking Open November 30, 2021 1 minute read Sequor Law Sequor Law Founding Shareholder Gregory Grossman spoke at IBRA-Instituto Brasilerio de Rastreamento de Ativos on Friday, November 26th. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. 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..

Sequor Law's Leyza B. Florin chairs the Lawyers Advisory Committee for the Southern District of Florida Bankruptcy Court, linking judges and practitioners to improve bankruptcy practice across the district. Lawyers Advisory Committee Open Awards & Recognition Open September 16, 2019 3 minutes read Sequor Law By: Guest Contributor Leyza B. Florin , Chair Lawyers Advisory Committee The Lawyers Advisory Committee (LAC) for the Southern District of Florida Bankruptcy Court was formed in 2018 to provide a forum for communication, feedback, and resources between the judges and the bar. Its purpose includes regularly soliciting the bar for commentary regarding bankruptcy practice and receiving requests from the court to consider issues arising from the practice of law before the Court. The LAC may recommend changes in the practice and procedures throughout the district and also acts as a liaison between the Court and the practitioners. In addition, the LAC is charged with the development, implementation, and maintenance of bankruptcy-related programs in the district as requested by the Court. To view samples of issues addressed by the LAC, please visit the LAC web page to view meeting minutes. The LAC is only as successful as the bankruptcy bar makes it. We are dependent on you to contact LAC members with any concerns or suggestions that you might have about bankruptcy practice in our district. The success of our bankruptcy practice in the Southern District of Florida is our absolute priority. If you have any recommendations which will improve the Court’s administration of justice, please reach out to a member of the LAC or contact us at LAC@flsb.uscourts.gov . We encourage you to participate by submitting feedback for consideration and assist the LAC in making our bankruptcy practice in the Southern District of Florida the best it can be. BANKRUPTCY RULES AND FORMS ARE AMENDED EFFECTIVE 12/1/19 Amendments to the federal rules and forms scheduled to take effect 12/1/19 and can be reviewed at the U.S. Courts website at these links: Pending Rules and Forms Amendments Pending Changes in Bankruptcy Forms If any of the above amendments necessitate changes in this court’s local rules, local forms, court guidelines, clerk’s instructions or any other local documents, notice will be provided prior to the December 1, 2019, effective date of the bankruptcy rules and forms amendments. COURT GUIDELINES FOR ATTORNEYS FOR CHAPTER 13 DEBTORS AMENDED Please take notice that the “Guidelines for Compensation for Professional Services or Reimbursement of Expenses by Attorneys for Chapter 13 Debtors Pursuant to Local Rule 2016-1(B)(2)(a)” have been amended to reflect an increase in the compensation fee that an attorney may charge without application to the court. The “no-look” fee will increase from $3,500 to $4,500 for all cases filed under or converted to chapter 13 on or after September 1, 2019. A Public Notice and amended “Guidelines” are currently posted on the court website. PROPOSED AMENDMENT TO THE FEDERAL RULES PUBLIC COMMENT PERIOD CLOSES FEBRUARY 19, 2020 On August 19, 2019, the Judicial Conference Advisory Committees on Appellate, Bankruptcy, and Civil Rules published proposed amendments to their respective rules and forms and requested that the proposals be circulated to the bar and public for comment. Appellate Rules: 3, 6, 42, and Forms 1 and 2; Bankruptcy Rules: 2005, 3007, 7007.1, and 9036; Civil Rule: 7.1 The proposed amendments, rules committee reports explaining the proposed changes, and instructions on how to submit comments are posted on the U.S. Courts website at: Proposed Amendments Published Comments The public comment period closes on February 19, 2020. If approved, the amendments would become effective December 1, 2021. 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 Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. 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..

Celebrating Bob Lindquist's 50-year career in forensic financial investigations. Sequor Law's Director of Forensics reflects on his storied journey from auditor to leading fraud investigator. Director of Forensics Bob Lindquist Celebrates 50-Year Career Milestone Open Firm News Open January 18, 2023 4 minutes read Sequor Law As we join Bob Lindquist in celebrating his 50 years in forensic financial investigations, let’s take a look back at his illustrious and storied career. It is one that has been filled with great successes, rewarding experiences and lessons learned along the way. It Started with a Challenge In January 1972, an audit partner at what is now Deloitte challenged Bob to decide whether he wanted to drive rally cars or be a professional auditor. Fun fact: he had won the Ontario Rally Championship the year before! Fast forward to February 1972, and Bob joined their insolvency group with the task to proof-read their draft report on the collapse of a mob-styled bank in Toronto that had captured the public’s attention. Bob was struck with its intrigue even though at the time he had no idea that financial investigations would become his career and forensic accounting, his profession. Read more here . In the early 1970’s, all auditors were auditing, and this allowed Bob to learn from both his good and bad experiences, especially the process of surviving cross-examination. Working with the prosecution taught him how to conduct an investigation and an interview, as well as how to write unbiased memos and reports. Most importantly, Bob learned the key element to any investigation: how to use discernment to find the truth. Lessons Learned and Advice for the Next Generation Petroleo Brasileiro SA, Brazil et al vs. U.S. Fidelity et al, 2000 – Ipanema Beach beckons, but you must dig until all is found out. Regina vs. Steele/Waddilove, 1976 – Be selective and do not become personally involved with a client’s case. Regina vs. Parks, 1974 – Avoid the use of any descriptive words and to state specifically only the information on the face of the documents. Why? Descriptive words are subjective and reflect bias, the number one enemy for an expert witness. IBM, Poughkeepsie, New York, Roger was Too Busy to Chat, 1993 – There are several issues to be addressed by the forensic accountant in a live internal investigation: ‘purity of the company,’ the ‘con versus con’ interview approach, a belief that the human element is at least as important as the accounting for numbers and most importantly among the employees, the forensic accountant must establish credibility otherwise voluntary information may not be forthcoming. London Life and The Anonymous Letter, 1986 – The forensic accountant has a crucial obligation to maintain the purity of a corporation or any operating division while conducting an investigation. It is imperative to limit the number of people who need to know the allegations. The forensic accountant must probe carefully and create the basis in a timely manner for an eventual meeting with the person who is the subject of the allegations. The time frame for the initial assessment is usually measured in days. Cases that Left an Impact One of Bob’s most complex cases involved Dormant Bank Accounts of Victims of the Holocaust, Switzerland , a search for the assets for the victims of the Holocaust in 1996-1998. For the forensic accountant, the human element is at least as important as the accounting for numbers. In this case of such historical tragedy, the human element could never (and we hope) ever be as significant. For Bob, a unique time (1½ years based in Basel) forever remembered, particularly brought home when you interview former management now in their eighties to experience their emotional recollection of the Holocaust. Another case that was perhaps Bob’s most frustrating was Government of Romania vs. former President Nicolai Ceausescu in 1990. He was hired to assist the new government through the Minister of Justice to find the assets of Ceausescu following the summary trial and swift execution of Nicolai Ceausescu and his wife, Elena. Assets were located in Cyprus but despite the promise of the Minister of Justice, the government never commenced legal proceedings as they walked into the shoes of Ceausescu. A Sample of 50 Years Worth of Career Highlights Supreme Court of Ontario and Case Precedent In January 1974, the Park’s case gave Bob the opportunity to sit with Crown Counsel Rod McLeod at the table through a jury trial. The presiding Judge Garth Moore ruled the accounting schedules admissible given what he described as the “veritable blizzard of documents”. As a result of this case ruling and others, in May 1978, the precedent for the admissibility of accounting schedules was recognized by the Supreme Court of Ontario based solely upon Bob’s cases. International Investigations that Result in Financial Recovery Bob enjoys the cultural challenge of international financial investigations. He has conducted many high profile investigations on behalf of corporations and governments in the United States, Antigua, Austria, Brazil, BVI, Canada, Chile, Grenada, Guatemala, Hong Kong, Isle of Man, Ivory Coast, Jamaica, Jersey, Netherlands, Malawi, Trinidad, Romania, St. Lucia, Switzerland and the United Kingdom. Government of Trinidad vs. Minister Johnny O Halloran, Mr. 10% – In the fall of 1988, Bob met Attorney General Selwyn Richardson in Port-of-Spain to determine if there was any merit to support the numerous allegations of bribery. This was the first time that a foreign country had successfully sued a U.S. company for bribery and made a recovery of US$7 million. Government of Antigua vs. Lester Bird et al in the ‘IHI’ Matter – In May 2004, the Attorney General retained Bob to investigate allegations of corruption regarding the former Bird government. In February 2009, the Attorney General issued a statement advising of the recovery of U.S. $12 million from the Rappaport family in Switzerland. Lisa Armoyan, Petitioner/Wife and Vrege Armoyan, Respondent/Husband – Bob conducted a search for the assets of the husband subsequent to the “Armoyan Final Judgment” that was in the amount of some $18 million. The asset search investigation delved into public and private companies of an international nature covering several years and resulted in a recovery of $13 million. Sequor Law is proud to have supported Bob throughout his career and we look forward to seeing all that he continues to accomplish and teach others. If you’d like to learn even more about Bob, visit his bio on our website here . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. 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..

Sequor Law announces partners Leyza B. Florin and Fernando Menendez joining the firm, marking significant growth for the firm founded just a year ago. Meet Our Newest Partners Open Firm News Open June 4, 2018 1 minute read Sequor Law Leyza B. Florin and Fernando Menendez have joined the Sequor Law team as partners, representing a significant expansion for the firm, founded just one year ago.  “The firm not only gains two outstanding lawyers with years of experience in insolvency, restructuring and commercial litigation, but their bilingual and multicultural heritage will add to the growth of our market leadership in international asset recovery and cross-border insolvency.” -- Ed Davis , Sequor Law Founding Shareholder Leyza B. Florin Leyza will focus her practice on a wide range of litigation and insolvency matters, including debt restructuring and representation of creditors, with special emphasis on complex business bankruptcy and commercial litigation matters. She is also a Florida Supreme Court Certified Civil Mediator. Fernando Menendez Fernando will focus his practice on a broad range of insolvency-related matters, including complex workouts, bankruptcy litigation involving preferences, fraudulent transfers, and complex contested matters, creditors’ rights and remedies, as well as the representation of foreign and domestic court-appointed trustees. Leyza remarked, “We are so pleased to be able to bring our practice to Sequor Law, a highly acclaimed international firm. We have known several of the lawyers at Sequor Law professionally for years and have long admired their practice. We have shared values and a common vision to render world-class legal services from a highly specialized and client-focused platform.” Greg Grossman , a Sequor Law founding Shareholder added: “Leyza and Fernando’s work ethic, tenacity and thought leadership epitomize the motto of Sequor Law: Relentless. Global. Pursuit.” We invite you to learn more about our two newest additions, as well as our entire Sequor Law team, at SequorLaw.com . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. 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..

The Southern District of Florida bankruptcy court adopted the Judicial Insolvency Network’s guidelines to foster court-to-court communication and cooperation in cross-border insolvency cases, a move welcomed by Sequor Law’s Gregory Grossman. Florida Bankruptcy Court Adopts JIN Guidelines Open In the News Open February 5, 2018 2 minutes read Sequor Law By Dominic Lawson The Chief Bankruptcy Judge for the Southern District of Florida has ordered the adoption of the Judicial Insolvency Network’s (JIN) Guidelines on court-to-court communication and cooperation – making Florida the third US state to sign up to them. Judge Laurel Myerson Isicoff made the administrative order on 1 February. Effective immediately, the order adopts 14 guidelines on communication and cooperation between courts in cross-border insolvency matters drafted by the JIN , a group of international judges who met for the first time in Singapore in October 2016. The guidelines are designed to improve coordination and cooperation between courts presiding over international insolvency cases in a bid to enhance efficiency and effectiveness. Gregory Grossman , a founding shareholder at Miami-based firm Sequor Law, which has filed more than two dozen Chapter 15 cases, tells GRR that the Southern District of Florida has the third most Chapter 15 filings in the United States, which “makes sense given Miami’s status as a gateway to Latin America and its significant ties to the Caribbean.” “These guidelines should foster the continued cooperation between US Bankruptcy Courts and the insolvency courts of the rest of the world by adding a framework for even more direct communications,” Grossman says, adding that his firm welcomes their adoption. The guidelines allow courts to communicate directly with each other and to give notice of proceedings to parties in other jurisdictions. They also state that courts should encourage cooperation between administrators of parallel proceedings on all aspects of a case. The JIN Guidelines received the “most important overall development” award at the GRR Charity Awards in June. On 1 February 2017, Singapore and the District of Delaware became the first jurisdictions to adopt the JIN guidelines. The Southern District of New York adopted the guidelines on 17 February and was followed by Bermuda in March. England and Wales adopted the guidelines in May , as did the BVI. New South Wales followed suit in September . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. 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..

Sequor Law partners Leyza B. Florin, Edward H. Davis Jr., Gregory Grossman, and Arnoldo Lacayo named to the inaugural Lawdragon 500 Leading US Bankruptcy & Restructuring Lawyers guide. The 2020 Lawdragon 500 Leading U.S. Bankruptcy & Restructuring Lawyers Open Awards & Recognition Open July 24, 2020 1 minute read Sequor Law 24 July 2020 Sequor Law Partners Leyza B. Florin , Edward H. Davis, Jr. , Gregory S. Grossman and Arnoldo “Arnie” Lacayo were named to the inaugural Lawdragon 500 Leading US Bankruptcy & Restructuring Lawyers guide. Included in the Global guide are lawyers with leading cross-border practices that “bring remarkable skills in financing, structuring, litigating and creating a pathway forward” for their clients. Open the article here Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. 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..

The U.S. Supreme Court unanimously rules that private and investor-state arbitration tribunals are not "foreign tribunals" under 28 U.S.C. § 1782, limiting its use in international arbitration discovery. US Supreme Court Rules on Use of Section 1782 in Support of Arbitration Proceedings Open Legal Insights Open July 8, 2022 1 minute read Sequor Law In a unanimous decision, the U.S. Supreme Court held that two arbitration tribunals—one private and one investor-state—did not constitute “foreign or international tribunal[s]” under 28 U.S.C. § 1782. The statute is widely used by litigants to obtain discovery “for use in a proceeding in a foreign or international tribunal.” The decision came after years with a split among the Courts of Appeals on the issue, particularly in the area of international private arbitration. In its 17-page decision, the Court analyzed the language of the statute and its history noting that § 1782’s purpose is comity. The Court reasoned that a broad reading of §1782 “would open district court doors to any interested person seeking assistance for proceedings before any private adjudicative body—a category broad enough to include everything from a commercial arbitration panel to a university’s student disciplinary tribunal.” Opting for a narrower construction, the Court held that “only governmental or intergovernmental adjudicative bodies constitute a ‘foreign or international tribunal’ under § 1782”, adding that, “[s]uch bodies are those that exercise governmental authority conferred by one nation or multiple nations.” More on the decision can be found here . Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. 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..

A federal judge confirms a $24.5M arbitration award under the New York Convention, clearing enforcement against sovereign bank assets. NY Judge Confirms Investment Co’s $24.5M Arbitration Award Open In the News Open August 26, 2020 2 minutes read Sequor Law A federal judge in the Southern District of New York confirmed a $24.5 million arbitration award in favor of Hong Kong based Super Perfect Investments Ltd. against Tajikistan’s Agroinvestbank Open Joint Stock Co. The decision came after the bank failed to respond to the enforcement petition by the August 17, 2020 deadline. Judge Jesse M. Furman found no genuine issue of material fact and granted summary judgment enforcing the award. The dispute stems from failed cotton supply contracts. In 2012, Agroinvestbank issued guarantees to Super Perfect tied to agreements for the purchase of 20,000 metric tons of cotton from Tajik company Levakan-M LLC. In February 2013, the bank issued an $11 million guarantee, which was later revised and split. When Levakan failed to deliver the cotton, Super Perfect sought payment under the $11 million guarantee. The bank refused, asserting that the original guarantee had been canceled and that a subsequent $6 million guarantee was never issued. In July 2017, a Swiss Chambers’ Arbitration Institution panel in Geneva ruled in favor of Super Perfect. The arbitrator determined that the revised $11 million guarantee remained valid and applied an 18% interest rate. The final award totaled $11 million in damages, $12.86 million in interest, and $739,668 in legal costs. Super Perfect petitioned the New York federal court to recognize the award under the New York Convention and Section 9 of the Federal Arbitration Act. The company argued that both the United States and Tajikistan are signatories to the Convention, giving the court subject matter jurisdiction. It also identified Agroinvestbank assets in the district, including a Citibank account, to establish quasi in rem jurisdiction and pursue enforcement. With no opposition filed, the court confirmed the award, clearing the way for enforcement against the bank’s U.S. assets. To read the full 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 Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. 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..

A practical analysis of asset sales under § 363 in Chapter 15 bankruptcy cases, addressing cross-border insolvency challenges and the role of foreign representatives in U.S. courts. Selling Assets in Chapter 15 Matters: Practical Considerations in Cross- Border Insolvencies Open Legal Insights Open August 26, 2019 9 minutes read Sequor Law Asset sales under § 363 of the U.S. Bankruptcy Code [1] have become a critical component of the bankruptcy practitioner’s arsenal, and a preferred avenue of monetizing a debtor’s assets. The process is generally straightforward, and the Bankruptcy Code provides the framework of how sales should proceed. U.S. practitioners have become well versed in the § 363 sale process and how to address recurring issues; however, chapter 15 of the Bankruptcy Code [2] adds an additional layer of complexity that must be observed and resolved carefully. When the U.S. adopted chapter 15, it codified the Model Law on Cross-Border Insolvency of the United Nations Commission on International Trade Law (“Model Law”). [3] Chapter 15 aimed to facilitate U.S. recognition of foreign insolvency proceedings and increase international cooperation among courts in cross-border insolvency cases. [4] However, the Model Law is a generic template for countries around to world to incorporate into their existing insolvency laws. [5] Therefore, chapter 15’s adoption has created both conflicts and gaps as to how practitioners utilize the Bankruptcy Code to aid and facilitate cross-border insolvencies. This article highlights how the application of and compliance with § 363 is an example of these conflicts and gaps, and it provides some thoughts on what to look out for and how to address some of these issues. First: Is Relief Under § 363 Available? Chapter 15 proceedings fork into two paths: one for foreign main proceedings and the second for foreign non-main proceedings. [6] Under § 1520 of the Bankruptcy Code, foreign main proceedings automatically obtain rights under a number of other Bankruptcy Code sections immediately upon recognition. [7] Section 1520, however, only applies to foreign main proceedings; foreign non-main proceedings do not receive any sort of automatic applications. One of the sections automatically applied to foreign main proceedings is the right to sell property under § 363. [8] Therefore, if your proceeding is a foreign main proceeding, you are automatically entitled to utilize § 363 wherever and whenever appropriate. Although § 363 is not automatically applied to non-main proceedings, it is still available, but it requires additional steps. Specifically, once a foreign non-main proceeding is recognized, relief must be sought from the court to authorize the application of § 363 to the proceedings. This request for relief is presented to the court under § 1521. Once the court grants the requested relief, the § 363 sale process becomes available to the non-main proceeding. Section 1521 is a broad section of chapter 15 that allows the court, upon recognition of the proceedings, to provide additional relief to the foreign representative subject to limitations of the Bankruptcy Code and U.S. laws. [9] As such, the section can be used to utilize other provisions of the Bankruptcy Code that are not explicitly adopted or automatically applied in chapter 15, if that is necessary to assist the foreign representative. Second: Which Assets Can Be Sold, and Which Court Approves the Sale? Section 541 of the Bankruptcy Code is largely inapplicable in a chapter 15 proceeding. [10] An estate is never created in a typical chapter 15 proceeding. Section 363 contemplates the sale of property of the estate, so which assets are allowed to be sold under § 363 in chapter 15 proceedings? [11] Section 1520’s adoption of § 363 modifies the section so that it applies to transfers of any interest of the debtor in property that is within the territorial jurisdiction of the U.S. to the same extent that the section would apply to property of an estate. [12] Therefore, the assets that can be sold under chapter 15 appear to be broader than in other bankruptcy contexts because it is not limited to the estate. Could this mean that a foreign representative could sell property of the debtor in the U.S., even if the debtor would have claimed it exempt, if the case were a domestic case? To date, there do not appear to be any cases deciding this point. In Fairfield Sentry, [13] the Second Circuit analyzed what chapter 15 means by “transfer of an interest of the debtor in property that is within the territorial jurisdiction of the United States.” [14] Fairfield Sentry LLC was a BVI investment fund that filed customer claims in the SIPA liquidation of the Bernard L. Madoff Investment Securities LLC (BLMIS). Fairfield Sentry invested approximately 95 percent of its assets with BLMIS when Bernard Madoff’s Ponzi scheme became public. [15] As a consequence, Fairfield Sentry was placed into liquidation in the BVI in 2009, and in 2010 the U.S. Bankruptcy Court for the Southern District of New York recognized the foreign main proceeding. [16] Fairfield Sentry ultimately decided it would sell the SIPA claims and entered into an agreement with Appellee Farnum Place, LLC to sell the claims for 31.125 percent of their value. [17] However, days after the parties entered into the agreement, the trustee for the BLMIS liquidation announced that he had entered into a settlement agreement that would increase the value of Fairfield Sentry’s SIPA claims from 32 percent to 50 percent of the total amount claimed. [18] This substantial increase created tension between Fairfield Sentry’s liquidators and Farnum. The liquidators sought to cancel the sale, and Farnum sought to enforce it. The BVI court approved the sale over the liquidators’ objections, but instructed the liquidators to question the U.S. Bankruptcy Court as to whether § 363 applied and whether the section required disapproval of the sale. [19] Thereafter, the U.S. Bankruptcy Court rejected the liquidators’ application for disapproval of the proposed sale, and the district court affirmed. However, the Second Circuit reversed the decisions of the lower courts on appeal, finding that the “property” in this case was the SIPA claims and that the SIPA claims were located in New York, “where the property could be assigned or transferred,” [20] and therefore that § 363 applied. The Second Circuit made clear that a bankruptcy court’s “principal responsibility … is to secure for the benefit of creditors the best possible bid,” and the sale of the SIPA claims was ultimately disapproved. [21] Fairfield Sentry solidified that § 363 applies in chapter 15 whenever the asset to be sold is within the U.S. Moreover, Fairfield Sentry also set a line on the extent that comity will have in chapter 15 proceedings, and § 363 sales in particular. The Second Circuit rejected Farnum’s arguments that deference to the BVI decision was required, and the opinion makes clear that the court of the jurisdiction where the asset to be sold is located is the court with the ultimate approval of the sale. Third: How Do I Give Notice, and Where Are Objections Heard? One of the trickiest portions of utilizing § 363 in chapter 15 proceedings may be complying with the procedural requirements of the sale — specifically, notice to creditors and the hearing requirement. [22] Whereas a creditor matrix is easily accessible in domestic bankruptcy proceedings, it is not always the case in cross-border proceedings. Chapter 15 does not require any schedules, a creditor matrix or a claims register. A chapter 15 case requires nothing more than an application, statement identifying the foreign proceedings, and evidence of the existence of the foreign proceeding and appointment of the foreign representative. [23] In addition to the lack of traditionally relied-upon creditor information, some foreign jurisdictions make it difficult to locate the necessary creditor information. Also, the foreign representative might not always be the trustee of the foreign main proceedings, and therefore might not have direct access to the list of creditors. Every foreign jurisdiction is unique, and there are many factors that could lead to delays in utilizing § 363 in chapter 15 proceedings. You must prepare as best as possible to avoid any such delays. Complicating matters further, sometimes the notice requirements in the foreign main jurisdiction might not comply with the requirements of the U.S. How, then, does one go about notifying the creditors, and what is considered sufficient notice? In In re Banco Santos S.A., [24] a chapter 15 case filed in the Southern District of Florida, Hon. Laurel M. Isicoff addressed the issue of notice in the context of approving a settlement in a chapter 15 proceeding, which may be applied in the context of a § 363 sale. There were two separate instances where notice was required in Banco Santos. In the first instance, the foreign representative requested a bar order in favor of certain settling parties, and in the second instance, the foreign representative did not. [25] The court considered the nature and implications and the requests of the foreign representative for each instance. In the first instance (which requested a bar order), the court determined that directly mailing to each creditor in Brazil would be required, and in the second instance (which did not require a bar order), the court determined that notice via publication in the Brazilian Gazette, which is sufficient under Brazilian law, was sufficient despite the fact that notice by publication is generally insufficient in domestic proceedings. [26] Judge Isicoff highlights in Banco Santos that in a chapter 15, the court has the ability and duty to look at the requests made and the nature and implications of the requests before making a determination. Ultimately, the more burdensome the request, the more stringent the notice requirement should be. Similar to Fairfield Sentry, the property and assets to be sold in Banco Santos were located within the territory of the U.S. Therefore, to ensure compliance with the notice and hearing requirements of § 363, Judge Isicoff conditionally approved the pending sale and ordered any objections thereto be filed in the U.S. Judge Isicoff also ordered the foreign representative to request an order in the foreign main proceedings instructing any creditor with an objection to file them in the U.S. [27] This process created a simplified procedure to obtain approval of a sale while consolidating all objections into the appropriate jurisdiction. Fourth: Who Can Assist in the Sales Process? More often than not, professional persons need to be retained to assist in a sales process (an appraiser, auctioneer, realtor, etc.). The Bankruptcy Code lays out a clear process for how to go about hiring professional persons, and provides limitations on their compensation. [28] However, none of the relevant sections, including §§ 329 and 330, were adopted in chapter 15. What recourse does the foreign representative have in situations where they enter into a bad deal with a professional person? Is the court then authorized to disapprove any agreements or appointments? Ideally, § 1521 would allow the court to adopt any section of the Bankruptcy Code necessary, but what happens in a situation where the appointment of a professional person and their compensation is approved in the foreign main jurisdiction, but the appointment and compensation (while acceptable in the foreign main jurisdiction) would normally be considered unconscionable in the U.S.? It follows that the rationale in Fairfield Sentry will also apply here, but this is another situation that has not yet been challenged. There are many benefits to the adoption of the Model Law through chapter 15, and utilization of chapter 15 has been steadily increasing since the chapter was enacted. This article addresses some of the methods of dealing with the gaps and conflicts created by chapter 15 and the general requirements of the Bankruptcy Code in the context of § 363 sales, although the dueling nature of two insolvency proceedings arising in two separate jurisdictions necessitates that bankruptcy practitioners be twice as diligent in their cases. [1] Title 11 of the U.S. Code (the “Bankruptcy Code”). [2] 11 U.S.C. §§ 1501-1532. [3] 11 U.S.C. § 1501. [4] See generally 11 U.S.C. § 1501. Help Center [5] See www.uncitral.org/uncitral/en/uncitral_texts/insolvency/1997Model.html . [6] “Foreign main proceeding” means a foreign proceeding pending in the country where the debtor has the center of its main interests. 11 U.S.C. § 1502 (4). “Foreign non-main proceeding” means a foreign proceeding, other than a foreign main proceeding, pending in a country where the debtor has an establishment. 11 U.S.C. § 1502 (5). [7] See generally 11 U.S.C. § 1520. [8] 11 U.S.C. § 1520(a)(2)-(3). [9] See 11 U.S.C. § 1507(a); see also § 1521(a)-(b). [10] Section 541 is only discussed in chapter 15 in relation to concurrent proceedings and in authorizing a representative of a domestic bankruptcy to act abroad; see 11 U.S.C. §§ 1528 (commencement of a case after recognition of foreign main proceeding) and 1505 (authorization to act in foreign country). [11] 11 U.S.C. § 363(b)(1). (the “trustee, after notice and a hearing, may use, sell, or lease, other than in the ordinary course of business, property of the estate…” (emphasis added); see also infra footnote 14. [12] 11 U.S.C. § 1520(a)(2). [13] In re Fairfield Sentry Ltd., 768 F.3d 239 (2d Cir. 2014). [14] See Fairfield Sentry, 768 F.3d at 244; see also § 1520(a)(2). [15] Id. at 241. [ 16] Id. [17] Id. at 242. [18] Id. [19] Id. at 243. [20] Id. at 244. [21] Fairfield Sentry, 768 F.3d at 246-47, quoting In re Fin. News Network Inc., 980 F.2d 165, 169 (2d Cir. 1992). [22] 11 U.S.C. § 363(b)(1) (“The trustee, after notice and a hearing, may use, sell, or lease…”) (emphasis added). [23] 11 U.S.C. § 1515. [24] In re Banco Santos S.A., Case No. 10-47543-BKC-LMI. [25] Banco Santos, Case No. 10-47543-BKC-LMI [D.E. 170, 184, 185]. [26] Id. [27] Id. [D.E. 170, 185]. [28] 11 U.S.C. §§ 327, 328. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. 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..

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 Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. 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..

Attorney Spotlight – Get to Know Alain M. Acanda Open Attorney Spotlight Open January 29, 2026 2 minutes read Sequor Law 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 child. Growing up I wanted to change the relationship I had with the law and use the legal field to build myself and my community up. 2. Why did you choose the areas of law that you practice? I chose the areas of law I practice because it allows me to take advantage of Miami’s unique position as a hub for the exchange of culture, business, and legal work. Practicing in areas like cross border insolvency and arbitration allows me to gain a broad range of perspectives from clients across the globe. 3. What skills do you draw upon when it comes to your specific practice areas? The skills I draw upon in my practice areas are understanding how all the moving pieces of a case fit together and being flexible in order to deliver results for the client. Being able to understand how these pieces fit together keeps a case moving forward and being flexible permits adapting to changing circumstances in order to still deliver for a client. 4. What is the most rewarding part about your job? The most rewarding part of the job is being able to deliver for a client. 5. Tell us about a mentor who made an impact on your career. A mentor who had an impact on my career was my high school AP European History teacher. He also served as my coach for the international debate club which was where I first became interested in international law which has carried on until today. 6. If you weren’t practicing law, what would you be doing? If I wasn’t practicing law, I’d either be a history professor or restoring classic American cars. 7. What might people be surprised to learn about you? People might be surprised to learn that I love to cook. Whether it be cooking steaks on a grill or making pasta from scratch, I enjoy trying new recipes and making different dishes. 8. What is a good book or article you read recently? A good book I read recently was : Cuba, An American History by Ada Ferrer. It explores the rich shared history between the two nations which can be often overlooked beyond the Castro-regime years. Open Back to all Entries Share this article Facebook X (Twitter) WhatsApp LinkedIn Copy link Latest News & Insights Open Open Attorney Spotlight Aug 17, 2026 3 minutes read Attorney Spotlight – Get to Know Carolina M. Rosso “Pour faire de grandes choses, il ne faut pas être un si grand génie... Firm News Jun 23, 2026 3 minutes Sequor Law Welcomes Attorney Carolina M. Rosso to Its Expanding International Litigation and Asset Recovery Team Sequor Law is pleased to announce that Carolina M. Rosso has joined the firm as an Attorney. 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..