Choice-of-Law Issues

The following session took place during the 2026 ABI International Caribbean Insolvency Symposium in January 2026. This panel will examine conflicts of laws in cross-border insolvency, focusing on U.S. standing rules versus foreign recovery statutes, offshore jurisdictional reach, and choice-of-law challenges. It will also provide practical strategies for planning around these issues to mitigate risk and achieve enforceable outcomes.

Watch On-Demand:
Insolvency OnDemand

Session Materials:
Download Materials (PDF)


Speakers:

John R. Dodd, Moderator
Baker & McKenzie LLP | Miami, FL

Shane Donovan
Mourant | British Virgin Islands, Road Town Tortola

Yonah Jaffe
Reid Collins & Tsai LLP | New York, NY

Christopher Levers
Ogier | Cayman Islands, George Town

Margot MacInnis
Grant Thornton LLP | Cayman Islands, Grand Cayman

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Conference
2026 ABI International Caribbean Insolvency Symposium
Date