Overview

This seminar will discuss the use of Singapore law as a governing law in cross-border lending transactions. We will cover some of the key implications that follow where a loan transaction is governed by Singapore law, including in relation to documentation, lending and collateral structures, enforcement and foreign recognition, and the effects of insolvency and the IRDA. We will also discuss some of the differences between English law and Singapore law, particularly in the context of insolvency, as well as the recent English decision in Prosafe and its implications for the choice of Singapore law cross-border financings.