How Hague Enforcement Initiative Compares To EU Regimes

Law360 (September 11, 2019, 4:26 PM EDT) -- The latest convention adopted by the Hague Conference on Private International Law, or HCCH, promises truly global cross-border enforcement. This convention may be an attractive option for the U.K. in the event of a no-deal Brexit. This article discusses this factor, and compares and contrasts the convention’s provisions with the existing European judgment recognition and enforcement frameworks.

If, on Oct. 31, the United Kingdom leaves the European Union without a deal, it is likely to lose access to important frameworks which provide for the reciprocal cross-border recognition and enforcement of civil judgments across Europe. Particularly at risk will be the 2007...

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