Debtwire Radio

Last year, the United Nations Commission on International Trade Law (UNCITRAL) Working Group V revealed a new Model Law on the Recognition and Enforcement of Insolvency-Related Judgments. This has been referred to as “UNCITRAL 2” or “UNCITRAL lite” and establishes a framework for recognition and enforcement of foreign insolvency judgments. Morrison & Foerster’s Sonya Van de Graaff and Kathlene Burke of Skadden – who, as first Co-Chair and current Co-Chair of the International Women’s Insolvency & Restructuring Confederation’s (IWIRC) London Network, were both involved in the preparation of the new Model Law – sat down with Debtwire Europe Legal Analyst Dawn Grocock and head of European court reporting Hossein Dabiri to discuss the new Model Law’s aims and the road to implementation, the impediments to universalism in the UK (including the controversial rule in Gibbs and the recent OJSC International Bank of Azerbaijan case) and the US position.