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Abstract: 

Judgments, orders, and settlement agreements obtained in home country insolvency proceedings face an uncertain reception when parties seek to enforce them abroad. The authors discuss the varied approaches to enforcement applied in London, Singapore, and by bankruptcy Judge Glenn in the Agrokor case in New York City. They address in detail Judge Glenn’s findings with respect to comity, discretionary relief, and due process in approving the enforcement of a settlement agreement entered into and approved in Agrokor’s Croatian insolvency proceeding.

Keywords: United Kingdom Approach: Rubin v. Eurofinance S.A.; Singapore Approach: Pacific Andes Resources Development Ltd.; New York Approach: In re Agrokor d.d.; Croatian Settlement Agreement

Affiliations:  1: Curtis, Mallet-Prevost, Colt & Mosle LLP; 2: Curtis.