# How Does the UNCITRAL Model Law Influence Cross-Border Insolvency Cases in the US? ▴ Question

**Published:** 2025-08-17
**Categories:** Question

---

![A polished, light surface interfaces with a darker, contoured form on black. This signifies the RFQ protocol for institutional digital asset derivatives, embodying price discovery and high-fidelity execution](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-interface.jpg)

![A central, blue-illuminated, crystalline structure symbolizes an institutional grade Crypto Derivatives OS facilitating RFQ protocol execution. Diagonal gradients represent aggregated liquidity and market microstructure converging for high-fidelity price discovery, optimizing multi-leg spread trading for digital asset options](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-engine-11.jpg)

## Concept

![A smooth, light grey arc meets a sharp, teal-blue plane on black. This abstract signifies Prime RFQ Protocol for Institutional Digital Asset Derivatives, illustrating Liquidity Aggregation, Price Discovery, High-Fidelity Execution, Capital Efficiency, Market Microstructure, Atomic Settlement](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-protocol-digital-asset-derivatives-execution-liquidity.jpg)

## The Global Standard for Insolvency Protocols

When capital flows across borders, the legal frameworks governing its potential distress must follow. The UNCITRAL Model Law on [Cross-Border Insolvency](https://prime.greeks.live/area/cross-border-insolvency/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) represents a pivotal development in the architecture of international commerce, establishing a standardized protocol for jurisdictions to recognize and cooperate on insolvency matters. Its influence on the United States legal system, codified as Chapter 15 of the U.S. Bankruptcy Code, provides a predictable and efficient channel for managing the complexities of multinational corporate distress. This framework is built upon the foundational principles of comity and cooperation, creating a system where a primary foreign [insolvency proceeding](https://prime.greeks.live/question/what-are-the-legal-risks-of-proceeding-with-an-rfp-that-has-flawed-criteria/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) is given deference, allowing for a centralized and coordinated administration of a debtor’s worldwide assets.

The adoption of this model law moves the process away from a fragmented, territory-by-territory liquidation toward a cohesive, global approach. This systemic integration is designed to enhance legal certainty for trade and investment, a core objective that underpins the entire structure.

The operational logic of the Model Law, and by extension Chapter 15, is to create a clear procedural gateway, not a substantive one. It does not seek to harmonize the underlying insolvency laws of different nations. Instead, it provides the necessary interface for these disparate systems to communicate and act in concert. A [foreign representative](https://prime.greeks.live/area/foreign-representative/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), appointed in a company’s primary jurisdiction, can petition a U.S. court for “recognition” of the [foreign proceeding](https://prime.greeks.live/question/what-are-the-legal-risks-of-proceeding-with-an-rfp-that-has-flawed-criteria/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite).

This act of recognition is the central mechanism through which the system functions. It grants the foreign representative direct access to U.S. courts, enabling them to protect the debtor’s local assets from seizure, gather evidence, and ensure that the U.S. portion of the insolvency is administered in a manner consistent with the main international effort. This protocol prevents the chaotic “race to the courthouse” by individual creditors in multiple jurisdictions, preserving value for all stakeholders by treating the insolvent entity as a single, global estate.

> The UNCITRAL Model Law provides a procedural framework into which local substantive bankruptcy law is integrated, creating a standardized protocol for international legal cooperation.

![A precise, multi-layered disk embodies a dynamic Volatility Surface or deep Liquidity Pool for Digital Asset Derivatives. Dual metallic probes symbolize Algorithmic Trading and RFQ protocol inquiries, driving Price Discovery and High-Fidelity Execution of Multi-Leg Spreads within a Principal's operational framework](https://options.greeks.live/wp-content/uploads/2025/07/institutional-grade-rfq-protocol-mechanism-for-digital-asset-derivatives-price-discovery-and-high-fidelity-execution-via-prime-os.jpg)

## Defining the Jurisdictional Tiers

The system’s intelligence lies in its differentiated approach to recognition, which is based on the concept of the debtor’s “center of main interests,” or COMI. This critical determination dictates the level of [automatic relief](https://prime.greeks.live/question/what-are-the-differences-between-a-stay-exception-and-a-motion-for-relief-from-stay/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) granted within the U.S. A “[foreign main proceeding](https://prime.greeks.live/area/foreign-main-proceeding/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite)” is one pending in the country where the debtor has its COMI ▴ the location where it conducts the administration of its interests on a regular basis and is therefore ascertainable by third parties. U.S. courts have established through precedent that while a debtor’s registered office creates a rebuttable presumption of COMI, the actual locus of nerve-center activities is the decisive factor.

This prevents the use of “letterbox” companies in offshore jurisdictions to manipulate the insolvency process. Recognition of a foreign main proceeding by a U.S. court triggers powerful, automatic protections, including the imposition of the [automatic stay](https://prime.greeks.live/area/automatic-stay/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) under section 362 of the [Bankruptcy Code](https://prime.greeks.live/area/bankruptcy-code/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), which halts all collection activities against the debtor’s property within the United States.

In contrast, a “foreign [non-main proceeding](https://prime.greeks.live/question/what-is-the-difference-between-main-and-non-main-foreign-proceedings/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite)” is recognized when it is pending in a country where the debtor has an “establishment” ▴ a place of operations where it carries out a nontransitory economic activity ▴ but not its COMI. Recognition of a non-main proceeding does not trigger automatic relief. Instead, it provides the foreign representative with standing to request discretionary relief from the U.S. court.

The court may, for instance, grant a stay, authorize discovery, or entrust the administration of U.S. assets to the foreign representative, but each action requires a specific request and judicial approval. This tiered structure allows the U.S. legal system to provide robust, immediate support to the primary insolvency proceeding while retaining judicial discretion to tailor relief appropriately for ancillary proceedings, ensuring that the interests of local creditors are sufficiently protected.

![Abstract planes delineate dark liquidity and a bright price discovery zone. Concentric circles signify volatility surface and order book dynamics for digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-high-fidelity-execution-3.jpg)

![Angular translucent teal structures intersect on a smooth base, reflecting light against a deep blue sphere. This embodies RFQ Protocol architecture, symbolizing High-Fidelity Execution for Digital Asset Derivatives](https://options.greeks.live/wp-content/uploads/2025/07/dynamic-rfq-protocol-architecture-optimizing-digital-asset-derivative-liquidity-aggregation.jpg)

## Strategy

![Translucent, multi-layered forms evoke an institutional RFQ engine, its propeller-like elements symbolizing high-fidelity execution and algorithmic trading. This depicts precise price discovery, deep liquidity pool dynamics, and capital efficiency within a Prime RFQ for digital asset derivatives block trades](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-engine-14.jpg)

## The Strategic Objectives of Chapter 15

The adoption of the [UNCITRAL Model Law](https://prime.greeks.live/area/uncitral-model-law/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) as Chapter 15 was a strategic move to align U.S. insolvency law with the realities of a globalized economy. The framework is engineered to achieve five specific, interconnected objectives that collectively enhance the stability and predictability of international trade and investment. The primary goal is to promote direct cooperation between U.S. courts and foreign courts and representatives.

The statute explicitly charges courts and estate representatives to “cooperate to the maximum extent possible,” authorizing direct communication to streamline the coordination of complex, parallel proceedings. This directive is a functional departure from older, more insular approaches to cross-border insolvency, establishing a clear policy preference for collaboration over jurisdictional conflict.

A second strategic pillar is the establishment of greater legal certainty. By creating a predictable set of rules for recognizing foreign proceedings and the relief that follows, Chapter 15 allows multinational enterprises, investors, and creditors to better assess and price risk. They can anticipate how a financial distress scenario will unfold, regardless of where the primary insolvency is filed, as long as the jurisdiction is a Model Law country. This certainty is complemented by the objective of fair and efficient administration, which protects the interests of all creditors, foreign and domestic.

Chapter 15 explicitly prohibits discrimination against foreign creditors and mandates that they receive proper notice of U.S. proceedings, ensuring they have the opportunity to participate and file claims. The final two objectives ▴ the maximization of the value of the debtor’s assets and the facilitation of corporate rescues ▴ are the ultimate economic outcomes of this enhanced cooperation and certainty. By preventing a piecemeal dismemberment of assets and centralizing administration, the framework increases the likelihood of a successful reorganization or a more valuable liquidation, preserving economic value and employment.

> Chapter 15 provides a flexible yet structured tool to assist with the administration of a foreign liquidation or debt restructuring, offering benefits that may not be available outside the U.S.

![A precise metallic cross, symbolizing principal trading and multi-leg spread structures, rests on a dark, reflective market microstructure surface. Glowing algorithmic trading pathways illustrate high-fidelity execution and latency optimization for institutional digital asset derivatives via private quotation](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-execution-architecture.jpg)

## Navigating the Recognition Process

The strategic core of a Chapter 15 case is the petition for recognition. The foreign representative’s primary task is to persuade a U.S. bankruptcy court that the foreign insolvency proceeding meets the statutory definitions of a “foreign proceeding” and that the representative is a “person or body” authorized to act on its behalf. The evidentiary requirements are specific ▴ the petition must be accompanied by a certified copy of the decision commencing the foreign proceeding and appointing the representative, or other evidence acceptable to the court.

All key documents must be translated into English. Success in this phase hinges on meticulously assembling this evidence to present a clear and irrefutable case for recognition.

A critical strategic decision is whether to seek recognition as a “main” or “non-main” proceeding. As the designation of “main proceeding” unlocks the powerful automatic stay, this is typically the primary objective. The strategy for proving COMI involves presenting evidence that the debtor’s headquarters, primary management, and main administrative functions are located in the foreign jurisdiction. This could include board meeting minutes, location of key executives, primary bank accounts, and correspondence with creditors.

Parties opposing recognition may strategically challenge the COMI designation, arguing, for example, that the debtor is merely a “letterbox” company and its true nerve center is elsewhere. Another defensive strategy for opponents is to invoke the public policy exception, arguing that recognition would be “manifestly contrary” to fundamental U.S. policies. However, legislative history and court precedent have confirmed this is an extremely narrow exception, typically reserved for situations involving egregious treatment of creditors, such as discrimination based on nationality, which would offend core U.S. legal principles.

![Abstract layered forms visualize market microstructure, featuring overlapping circles as liquidity pools and order book dynamics. A prominent diagonal band signifies RFQ protocol pathways, enabling high-fidelity execution and price discovery for institutional digital asset derivatives, hinting at dark liquidity and capital efficiency](https://options.greeks.live/wp-content/uploads/2025/07/high-fidelity-institutional-digital-asset-derivatives-rfq-protocol.jpg)

## Comparative Frameworks Pre and Post Chapter 15

To fully appreciate the strategic shift introduced by Chapter 15, it is useful to compare its systematic approach with the framework it replaced, section 304 of the Bankruptcy Code. The table below illustrates the evolution from a discretionary, unpredictable system to a standardized, protocol-driven one.

| Feature | Former Section 304 Framework | Chapter 15 (UNCITRAL Model Law) Framework |
| --- | --- | --- |
| Basis for Relief | Discretionary comity; courts conducted a multi-factor analysis that could lead to inconsistent outcomes. | Standardized recognition process based on defined terms like “foreign main proceeding” and COMI. |
| Automatic Relief | No automatic relief was available upon filing. All relief, including stays, required a specific court order. | Recognition of a “foreign main proceeding” triggers the automatic stay under § 362 of the Bankruptcy Code. |
| Foreign Representative Access | Limited access; the representative could seek to enjoin actions but had less direct standing. | Direct access to U.S. federal and state courts upon recognition. |
| Cooperation Mandate | No explicit statutory mandate for cooperation. Communication between courts was ad hoc and rare. | Explicit statutory duty for courts and representatives to cooperate to the maximum extent possible (§§ 1525-1527). |
| Predictability | Low. Outcomes were highly dependent on the specific judge and district, creating uncertainty for creditors. | High. The protocol-based system provides greater legal certainty for international trade and investment. |

![Institutional-grade infrastructure supports a translucent circular interface, displaying real-time market microstructure for digital asset derivatives price discovery. Geometric forms symbolize precise RFQ protocol execution, enabling high-fidelity multi-leg spread trading, optimizing capital efficiency and mitigating systemic risk](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-request-for-quote-protocol-high-fidelity-execution-market-microstructure-intelligence-layer.jpg)

![A modular component, resembling an RFQ gateway, with multiple connection points, intersects a high-fidelity execution pathway. This pathway extends towards a deep, optimized liquidity pool, illustrating robust market microstructure for institutional digital asset derivatives trading and atomic settlement](https://options.greeks.live/wp-content/uploads/2025/07/rfq-protocol-layer-connecting-institutional-digital-asset-liquidity-pools.jpg)

## Execution

![Two smooth, teal spheres, representing institutional liquidity pools, precisely balance a metallic object, symbolizing a block trade executed via RFQ protocol. This depicts high-fidelity execution, optimizing price discovery and capital efficiency within a Principal's operational framework for digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/precision-execution-bridging-institutional-liquidity-pools-via-rfq-protocol-for-optimized-digital-asset-derivatives-price-discovery.jpg)

## The Procedural Workflow of a Chapter 15 Case

The execution of a Chapter 15 case follows a structured, multi-stage process designed for efficiency and predictability. The process begins long before any court filing, with the foreign representative and their U.S. counsel gathering the extensive documentation required to support the petition for recognition. This initial phase is critical, as the success of the petition depends on the quality and completeness of the evidentiary record presented to the U.S. court. Once the petition is filed, the process moves into the judicial phase, where the court considers recognition and the granting of relief.

- 
**Petition and Documentation Assembly.** The foreign representative must compile a petition for recognition that includes statutorily required documents. This package serves as the foundation of the case. It must contain:

<li>A certified copy of the order from the foreign court that commenced the insolvency proceeding and appointed the foreign representative.

- Alternatively, a certificate from the foreign court or other evidence demonstrating the existence of the proceeding and the representative’s authority.

- A statement identifying all other known foreign proceedings concerning the debtor.

- English translations of all supporting documents.

</li>
- 
**Filing and Provisional Relief.** The petition is filed in the U.S. bankruptcy court in the district where the debtor’s principal U.S. assets are located or where it is a defendant in a lawsuit. Upon filing, and before the court rules on recognition, the foreign representative can request provisional relief if “urgently needed to protect the assets of the debtor or the interests of creditors.” This could include a temporary stay on actions against the debtor’s U.S. assets.

- 
**The Recognition Hearing.** The court schedules a hearing on the petition for recognition. Interested parties, such as U.S. creditors, are given notice and an opportunity to object. At the hearing, the court determines if the foreign proceeding qualifies as a “foreign main” or “foreign non-main” proceeding and if the petitioner qualifies as a “foreign representative.”

- 
**The Recognition Order and Its Consequences.** If the court grants the petition, it enters an order for recognition. The effects of this order are profound and depend on the main/non-main designation:

<li>**Main Proceeding** ▴ The automatic stay of 11 U.S.C. § 362 immediately applies to the debtor and its property in the U.S. The foreign representative is empowered to operate the debtor’s business in the ordinary course.

- **Non-Main Proceeding** ▴ No automatic relief is granted. The foreign representative gains standing to request specific, discretionary relief from the court.

</li>
- 
**Post-Recognition Administration.** Following recognition, the foreign representative administers the debtor’s U.S. assets and affairs. This can involve seeking additional “permissive relief,” conducting discovery, initiating litigation (such as avoidance actions, if a full Chapter 7 or 11 case is also commenced), and coordinating with the foreign court to ensure a harmonized administration of the global estate. The representative also has an ongoing duty to inform the U.S. court of any substantial change in the status of the foreign proceeding.

> The deliberately flexible nature of Chapter 15 is designed to accommodate administrative differences among international insolvency proceedings, facilitating a coordinated global resolution.

![A central core, symbolizing a Crypto Derivatives OS and Liquidity Pool, is intersected by two abstract elements. These represent Multi-Leg Spread and Cross-Asset Derivatives executed via RFQ Protocol](https://options.greeks.live/wp-content/uploads/2025/07/digital-asset-derivatives-rfq-protocol-multi-leg-spread-execution.jpg)

## A Taxonomy of Available Judicial Relief

The relief available under Chapter 15 is a critical component of its effectiveness, providing the foreign representative with the tools needed to protect and administer the debtor’s U.S. assets. This relief is categorized into three distinct phases, each tied to a specific stage of the Chapter 15 case. The following table details the types of relief available, the relevant statutory authority, and the conditions for granting it.

| Type of Relief | Statutory Authority (11 U.S.C.) | Description and Conditions |
| --- | --- | --- |
| Provisional Relief | § 1519 | Granted after the petition is filed but before recognition. The court may grant a temporary stay or other relief only if it is “urgently needed” to protect the debtor’s assets or creditor interests. This is a high standard to meet. |
| Automatic Relief | § 1520 | Triggered immediately and automatically upon the recognition of a “foreign main proceeding.” This includes the full force of the automatic stay under § 362 and the right for the foreign representative to operate the debtor’s business. |
| Permissive Relief | § 1521 | Available after recognition of either a main or non-main proceeding. The foreign representative must petition the court for this relief. It can include staying actions, suspending the right to transfer property, providing for the examination of witnesses, and entrusting assets to the foreign representative. |
| Participation in Other Cases | § 1512, § 1524 | Upon recognition, the foreign representative is authorized to participate as a party in interest in any pending U.S. insolvency case concerning the debtor and may intervene in other U.S. court cases where the debtor is a party. |
| Commencement of Plenary Case | § 1511 | After recognition, a foreign representative may commence a full bankruptcy case under Chapter 7 (liquidation) or Chapter 11 (reorganization) if the debtor has assets in the U.S. This is a strategic choice to access powers not available in Chapter 15 alone, such as avoidance actions. |

![Transparent conduits and metallic components abstractly depict institutional digital asset derivatives trading. Symbolizing cross-protocol RFQ execution, multi-leg spreads, and high-fidelity atomic settlement across aggregated liquidity pools, it reflects prime brokerage infrastructure](https://options.greeks.live/wp-content/uploads/2025/07/cross-protocol-rfq-execution-digital-asset-derivatives-microstructure-system.jpg)

## Recent Filing Data and Jurisdictional Trends

The practical application of Chapter 15 is reflected in its filing statistics. In 2023, a total of 49 new Chapter 15 petitions were filed across the [United States](https://prime.greeks.live/question/how-does-the-regulatory-environment-for-dark-pools-differ-between-the-united-states-and-other-major-financial-markets/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite), seeking recognition of proceedings from a diverse range of countries. This data highlights the law’s continued importance in global commerce. An analysis of the venues for these filings reveals a significant concentration in key financial and commercial centers, which is expected given the nature of cross-border business.

- 
**Southern District of New York** ▴ This district saw the highest number of filings, with 16 petitions in 2023. Its prominence reflects New York City’s status as a global financial hub, where many international companies have assets or conduct business.

- 
**Southern District of Florida** ▴ Ten petitions were filed in this district, indicating its growing importance as a nexus for business and investment, particularly related to Latin America.

- 
**District of Delaware** ▴ This district also had ten filings. Delaware is the corporate domicile for a vast number of U.S. and international companies, making it a natural venue for Chapter 15 cases even if the debtor’s operational assets are elsewhere.

The remaining thirteen cases were distributed across seven other districts, demonstrating the nationwide applicability of the law. The originating countries of these foreign proceedings in 2023 included major trading partners like Canada, the United Kingdom, and Germany, as well as financial centers such as Bermuda, the Cayman Islands, and Hong Kong, illustrating the truly global reach of the [UNCITRAL Model](https://prime.greeks.live/question/what-is-the-relationship-between-the-uncitral-model-law-and-the-isda-master-agreement/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite) Law’s influence through its U.S. implementation.

![Angular, reflective structures symbolize an institutional-grade Prime RFQ enabling high-fidelity execution for digital asset derivatives. A distinct, glowing sphere embodies an atomic settlement or RFQ inquiry, highlighting dark liquidity access and best execution within market microstructure](https://options.greeks.live/wp-content/uploads/2025/08/prime-os-digital-asset-derivatives-rfq-execution-protocol.jpg)

## References

- United States Courts. “Chapter 15 – Bankruptcy Basics.” uscourts.gov. Accessed August 17, 2025.

- Keenan, Paul, Mark Bloom, and James Leshaw. “Chapter 15 ▴ the US cross-border insolvency law.” PLC Cross-border Restructuring and Insolvency Handbook 2007/08, Practical Law Company, 2007.

- Vazquez, Francisco. “Year in review ▴ Significant US Chapter 15 decisions in 2023.” Norton Rose Fulbright, Q2 2024.

- Federal Judicial Center. “Managing the Chapter 15 Cross-Border Insolvency Case ▴ A Pocket Guide for Judges.” fjc.gov, 2010.

- UNCITRAL. “UNCITRAL Model Law on Cross-Border Insolvency with Guide to Enactment and Interpretation.” United Nations, 2014.

![Intersecting sleek components of a Crypto Derivatives OS symbolize RFQ Protocol for Institutional Grade Digital Asset Derivatives. Luminous internal segments represent dynamic Liquidity Pool management and Market Microstructure insights, facilitating High-Fidelity Execution for Block Trade strategies within a Prime Brokerage framework](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-high-fidelity-engine.jpg)

## Reflection

![Dark, pointed instruments intersect, bisected by a luminous stream, against angular planes. This embodies institutional RFQ protocol driving cross-asset execution of digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-best-execution-system-architecture.jpg)

## A System for Global Financial Stability

The integration of the UNCITRAL Model Law into the U.S. legal system is a testament to the understanding that in a deeply interconnected global economy, legal frameworks cannot remain isolated. Chapter 15 functions as a critical piece of financial infrastructure, a protocol that allows for the orderly resolution of distress across jurisdictions. Its existence provides a foundational layer of stability, reducing the systemic risk that would arise from chaotic, uncoordinated liquidations of multinational corporations. For the institutional investor, the corporate strategist, or the risk manager, understanding this system is not merely a matter of legal compliance.

It is about perceiving the architecture of global commerce itself. The principles of cooperation, recognition, and centralized administration embedded in the law are the very same principles that allow for the efficient allocation of capital on a global scale. The framework acknowledges that a debtor’s value is often a function of its continued operation as a whole, a whole that transcends national borders. The question for any enterprise operating on the global stage is how its own internal risk and governance structures align with this established international protocol for managing financial distress.

![Engineered components in beige, blue, and metallic tones form a complex, layered structure. This embodies the intricate market microstructure of institutional digital asset derivatives, illustrating a sophisticated RFQ protocol framework for optimizing price discovery, high-fidelity execution, and managing counterparty risk within multi-leg spreads on a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-stack-optimization.jpg)

## Glossary

<a href="https://prime.greeks.live/area/cross-border-insolvency/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Abstract institutional-grade Crypto Derivatives OS. Metallic trusses depict market microstructure](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-market-microstructure-optimizing-rfq-protocols-for-high-fidelity-execution-via-prime-os.jpg)

## Cross-Border Insolvency

Meaning ▴ Cross-Border Insolvency defines the procedural and legal framework for addressing the financial distress of an entity possessing assets, liabilities, or operational footprints across multiple national jurisdictions. </a><a href="https://prime.greeks.live/question/what-are-the-legal-risks-of-proceeding-with-an-rfp-that-has-flawed-criteria/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Abstract geometric planes in grey, gold, and teal symbolize a Prime RFQ for Digital Asset Derivatives, representing high-fidelity execution via RFQ protocol. It drives real-time price discovery within complex market microstructure, optimizing capital efficiency for multi-leg spread strategies](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-protocol-digital-asset-derivatives-high-fidelity-execution.jpg)

## Insolvency Proceeding

Flawed RFP criteria create direct legal and financial liabilities by breaching the implied contract of fair dealing with all bidders. </a><a href="https://prime.greeks.live/area/foreign-representative/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A golden rod, symbolizing RFQ initiation, converges with a teal crystalline matching engine atop a liquidity pool sphere. This illustrates high-fidelity execution within market microstructure, facilitating price discovery for multi-leg spread strategies on a Prime RFQ](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-systemic-core.jpg)

## Foreign Representative

Meaning ▴ A Foreign Representative designates an authorized entity or system module acting on behalf of a foreign institutional principal to facilitate direct engagement within a specific domestic digital asset derivatives market. </a><a href="https://prime.greeks.live/question/what-are-the-legal-risks-of-proceeding-with-an-rfp-that-has-flawed-criteria/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Modular institutional-grade execution system components reveal luminous green data pathways, symbolizing high-fidelity cross-asset connectivity. This depicts intricate market microstructure facilitating RFQ protocol integration for atomic settlement of digital asset derivatives within a Principal's operational framework, underpinned by a Prime RFQ intelligence layer](https://options.greeks.live/wp-content/uploads/2025/07/modular-high-fidelity-execution-architecture-for-institutional-digital-asset-derivatives-rfq-protocol-integration-and-principals-operational-framework-optimization.jpg)

## Foreign Proceeding

Flawed RFP criteria create direct legal and financial liabilities by breaching the implied contract of fair dealing with all bidders. </a><a href="https://prime.greeks.live/area/foreign-main-proceeding/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A metallic, cross-shaped mechanism centrally positioned on a highly reflective, circular silicon wafer. The surrounding border reveals intricate circuit board patterns, signifying the underlying Prime RFQ and intelligence layer](https://options.greeks.live/wp-content/uploads/2025/08/the-core-institutional-digital-asset-derivatives-rfq-os-engine-for-high-fidelity-market-microstructure.jpg)

## Foreign Main Proceeding

Meaning ▴ The Foreign Main Proceeding designates a primary insolvency or restructuring process initiated in a foreign jurisdiction where the debtor's center of main interests (COMI) resides. </a><a href="https://prime.greeks.live/question/what-are-the-differences-between-a-stay-exception-and-a-motion-for-relief-from-stay/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![An abstract digital interface features a dark circular screen with two luminous dots, one teal and one grey, symbolizing active and pending private quotation statuses within an RFQ protocol. Below, sharp parallel lines in black, beige, and grey delineate distinct liquidity pools and execution pathways for multi-leg spread strategies, reflecting market microstructure and high-fidelity execution for institutional grade digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-displaying-multi-leg-execution-status-and-optimal-liquidity-pathways.jpg)

## Automatic Relief

A stay exception is a statutory, self-executing carve-out from bankruptcy's automatic stay; a motion for relief is a formal, court-adjudicated request to lift it. </a><a href="https://prime.greeks.live/area/bankruptcy-code/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Precision cross-section of an institutional digital asset derivatives system, revealing intricate market microstructure. Toroidal halves represent interconnected liquidity pools, centrally driven by an RFQ protocol](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-prime-os-architecture-revealing-precision-rfq-protocol-engine-for-optimal-high-fidelity-execution-and-latent-liquidity-aggregation.jpg)

## Bankruptcy Code

Meaning ▴ The Bankruptcy Code represents the foundational statutory framework within the United States legal system that governs the process for individuals and entities to resolve their unmanageable debts or liquidate assets. </a><a href="https://prime.greeks.live/area/automatic-stay/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek, dark teal, curved component showcases a silver-grey metallic strip with precise perforations and a central slot. This embodies a Prime RFQ interface for institutional digital asset derivatives, representing high-fidelity execution pathways and FIX Protocol integration](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine.jpg)

## Automatic Stay

Meaning ▴ The automatic stay constitutes a legally mandated or system-enforced cessation of specific actions against a distressed entity upon the occurrence of a predefined event, typically a default or insolvency filing. </a><a href="https://prime.greeks.live/question/what-is-the-difference-between-main-and-non-main-foreign-proceedings/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![A sleek, futuristic object with a glowing line and intricate metallic core, symbolizing a Prime RFQ for institutional digital asset derivatives. It represents a sophisticated RFQ protocol engine enabling high-fidelity execution, liquidity aggregation, atomic settlement, and capital efficiency for multi-leg spreads](https://options.greeks.live/wp-content/uploads/2025/07/advanced-institutional-digital-asset-derivatives-rfq-protocol-execution-engine-for-optimal-liquidity-aggregation-and-atomic-settlement.jpg)

## Non-Main Proceeding

The main proceeding is at the debtor's core operational hub, granting automatic relief; the non-main is at a local branch, requiring discretionary court aid. </a><a href="https://prime.greeks.live/area/uncitral-model-law/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Abstract forms representing a Principal-to-Principal negotiation within an RFQ protocol. The precision of high-fidelity execution is evident in the seamless interaction of components, symbolizing liquidity aggregation and market microstructure optimization for digital asset derivatives](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-protocol-execution-engine.jpg)

## Uncitral Model Law

Meaning ▴ The UNCITRAL Model Law represents a legislative template developed by the United Nations Commission on International Trade Law, designed to provide states with a standardized framework for modernizing their laws governing electronic commerce and digital transactions. </a><a href="https://prime.greeks.live/question/how-does-the-regulatory-environment-for-dark-pools-differ-between-the-united-states-and-other-major-financial-markets/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Central mechanical pivot with a green linear element diagonally traversing, depicting a robust RFQ protocol engine for institutional digital asset derivatives. This signifies high-fidelity execution of aggregated inquiry and price discovery, ensuring capital efficiency within complex market microstructure and order book dynamics](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-engine-best-execution.jpg)

## United States

US dark pool rules focus on operational disclosure, while EU rules impose hard volume caps to protect lit markets. </a><a href="https://prime.greeks.live/question/what-is-the-relationship-between-the-uncitral-model-law-and-the-isda-master-agreement/?utm_source=options.greeks.live&utm_medium=referral&utm_campaign=satellite" class="glossary-item-box">
![Abstract representation of a central RFQ hub facilitating high-fidelity execution of institutional digital asset derivatives. Two aggregated inquiries or block trades traverse the liquidity aggregation engine, signifying price discovery and atomic settlement within a prime brokerage framework](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-hub-core.jpg)

## Uncitral Model

The ISDA Agreement is the contract; the UNCITRAL Model Law is the globally enforceable operating system for arbitrating its disputes. </a>

**Tags:** [Chapter 15 Bankruptcy](https://options.greeks.live/area/chapter-15-bankruptcy/), [Foreign Main Proceeding](https://options.greeks.live/area/foreign-main-proceeding/), [Foreign Representative](https://options.greeks.live/area/foreign-representative/), [UNCITRAL Model Law](https://options.greeks.live/area/uncitral-model-law/), [Permissive Relief](https://options.greeks.live/area/permissive-relief/), [International Comity](https://options.greeks.live/area/international-comity/)	

## Discover More

- 
### [How Do Safe Harbors in the U.S. Bankruptcy Code Protect Financial Contracts?](https://options.greeks.live/question/how-do-safe-harbors-in-the-u-s-bankruptcy-code-protect-financial-contracts/)
![Sleek, domed institutional-grade interface with glowing green and blue indicators highlights active RFQ protocols and price discovery. This signifies high-fidelity execution within a Prime RFQ for digital asset derivatives, ensuring real-time liquidity and capital efficiency.](https://options.greeks.live/wp-content/uploads/2025/08/institutional-digital-asset-derivatives-rfq-prime-os-execution-interface.jpg)

The U.S. Bankruptcy Code's safe harbors shield financial contracts from the automatic stay, enabling immediate termination and netting to prevent systemic risk.

- 
### [What Are the Primary Legal and Jurisdictional Challenges to Enforcing Netting Agreements Globally?](https://options.greeks.live/question/what-are-the-primary-legal-and-jurisdictional-challenges-to-enforcing-netting-agreements-globally/)
![Visualizing a complex Institutional RFQ ecosystem, angular forms represent multi-leg spread execution pathways and dark liquidity integration. A sharp, precise point symbolizes high-fidelity execution for digital asset derivatives, highlighting atomic settlement within a Prime RFQ framework. This abstract composition conveys advanced market microstructure for price discovery.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocols-high-fidelity-execution-1.jpg)

The primary challenge to enforcing netting agreements is the conflict between private contracts and sovereign insolvency laws across divergent jurisdictions.

- 
### [What Constitutes a Financial Institution Having a Beneficial Interest Post Merit?](https://options.greeks.live/question/what-constitutes-a-financial-institution-having-a-beneficial-interest-post-merit/)
![A sharp, dark, precision-engineered element, indicative of a targeted RFQ protocol for institutional digital asset derivatives, traverses a secure liquidity aggregation conduit. This interaction occurs within a robust market microstructure platform, symbolizing high-fidelity execution and atomic settlement under a Principal's operational framework for best execution.](https://options.greeks.live/wp-content/uploads/2025/07/principal-grade-digital-asset-derivatives-rfq-protocol-execution-engine.jpg)

A financial institution has a beneficial interest post-Merit when it is the transaction's true economic recipient, not a mere conduit.

- 
### [Can a Junior Creditor Object to a Cash Collateral Agreement between the DIP and a Senior Lender?](https://options.greeks.live/question/can-a-junior-creditor-object-to-a-cash-collateral-agreement-between-the-dip-and-a-senior-lender/)
![A sharp, metallic form with a precise aperture visually represents High-Fidelity Execution for Institutional Digital Asset Derivatives. This signifies optimal Price Discovery and minimal Slippage within RFQ protocols, navigating complex Market Microstructure. The background implies diverse Liquidity Pools and Capital Efficiency on a Principal's Prime RFQ.](https://options.greeks.live/wp-content/uploads/2025/07/precision-execution-institutional-digital-asset-derivatives-rfq.jpg)

A junior creditor can object to a cash collateral agreement to demand adequate protection against the erosion of its collateral value.

- 
### [How Does a Bidder Formally Protest a Perceived Procedural Error in a Public Procurement Process?](https://options.greeks.live/question/how-does-a-bidder-formally-protest-a-perceived-procedural-error-in-a-public-procurement-process/)
![A central core represents a Prime RFQ engine, facilitating high-fidelity execution. Transparent, layered structures denote aggregated liquidity pools and multi-leg spread strategies. Internal patterns symbolize market microstructure data streams, enabling algorithmic pricing and optimal price discovery for institutional digital asset derivatives.](https://options.greeks.live/wp-content/uploads/2025/07/prime-os-rfq-engine-for-institutional-digital-asset-derivatives-execution.jpg)

A bidder formally protests a perceived procedural error by filing a written objection with the contracting agency, the GAO, or the COFC.

- 
### [What Is the Primary Purpose of the Automatic Stay in a Bankruptcy Proceeding?](https://options.greeks.live/question/what-is-the-primary-purpose-of-the-automatic-stay-in-a-bankruptcy-proceeding/)
![Intersecting metallic components symbolize an institutional RFQ Protocol framework. This system enables High-Fidelity Execution and Atomic Settlement for Digital Asset Derivatives. Precise connections reflect Market Microstructure efficiency, supporting Multi-Leg Spread strategies within a Principal's Operational Framework, optimizing Capital Efficiency.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-system-specialists.jpg)

The automatic stay imposes a mandatory, system-wide pause on creditor actions to enable debtor reorganization and ensure equitable asset distribution.

- 
### [How Can a Master Netting Agreement Be Legally Challenged during a Cross-Border Bankruptcy Proceeding?](https://options.greeks.live/question/how-can-a-master-netting-agreement-be-legally-challenged-during-a-cross-border-bankruptcy-proceeding/)
![A golden rod, symbolizing RFQ initiation, converges with a teal crystalline matching engine atop a liquidity pool sphere. This illustrates high-fidelity execution within market microstructure, facilitating price discovery for multi-leg spread strategies on a Prime RFQ.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-systemic-core.jpg)

A Master Netting Agreement is challenged in cross-border bankruptcy by exploiting conflicts between national insolvency laws.

- 
### [What Is the Role of Isda’s Netting Opinions in Cross Border Insolvency Proceedings?](https://options.greeks.live/question/what-is-the-role-of-isdas-netting-opinions-in-cross-border-insolvency-proceedings/)
![A sleek, split capsule object reveals an internal glowing teal light connecting its two halves, symbolizing a secure, high-fidelity RFQ protocol facilitating atomic settlement for institutional digital asset derivatives. This represents the precise execution of multi-leg spread strategies within a principal's operational framework, ensuring optimal liquidity aggregation.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-protocol-execution-system-2.jpg)

ISDA's netting opinions provide the critical legal certainty required to enforce close-out netting across jurisdictions, transforming systemic risk into manageable, capital-efficient exposures.

- 
### [What Are the Legal Prerequisites for a Netting Agreement to Be Enforceable in Bankruptcy?](https://options.greeks.live/question/what-are-the-legal-prerequisites-for-a-netting-agreement-to-be-enforceable-in-bankruptcy/)
![Abstract visualization of an institutional-grade digital asset derivatives execution engine. Its segmented core and reflective arcs depict advanced RFQ protocols, real-time price discovery, and dynamic market microstructure, optimizing high-fidelity execution and capital efficiency for block trades within a Principal's framework.](https://options.greeks.live/wp-content/uploads/2025/07/institutional-digital-asset-derivatives-rfq-execution-engine-interface.jpg)

A netting agreement's enforceability in bankruptcy hinges on its qualification as a master netting agreement covering QFCs between eligible financial participants.

---

## Raw Schema Data

```json
{
    "@context": "https://schema.org",
    "@type": "BreadcrumbList",
    "itemListElement": [
        {
            "@type": "ListItem",
            "position": 1,
            "name": "Home",
            "item": "https://options.greeks.live"
        },
        {
            "@type": "ListItem",
            "position": 2,
            "name": "Question",
            "item": "https://options.greeks.live/question/"
        },
        {
            "@type": "ListItem",
            "position": 3,
            "name": "How Does the UNCITRAL Model Law Influence Cross-Border Insolvency Cases in the US?",
            "item": "https://options.greeks.live/question/how-does-the-uncitral-model-law-influence-cross-border-insolvency-cases-in-the-us/"
        }
    ]
}
```

```json
{
    "@context": "https://schema.org",
    "@type": "Organization",
    "@id": "https://greeks.live/#organization",
    "name": "Greeks.Live",
    "url": "https://greeks.live/",
    "description": "Greeks.live is the definitive toolkit for the professional options trader, dedicated to empowering our users with institutional-grade data, advanced analytics, and a comprehensive suite of trading tools designed to provide a decisive edge in the market. Every article and guide published under the Greeks.live name is a product of our deep commitment to data-driven analysis and our mission to support the global trading community.",
    "email": "support@greeks.live",
    "logo": {
        "@type": "ImageObject",
        "url": "https://options.greeks.live/wp-content/uploads/2025/07/Greeks.Live-Logo-Icon.svg"
    },
    "hasPart": [
        {
            "@type": "WebSite",
            "name": "About Us",
            "url": "https://about.greeks.live"
        },
        {
            "@type": "WebSite",
            "name": "App Download Page",
            "url": "https://about.greeks.live/#/download/basic_trade"
        },
        {
            "@type": "WebSite",
            "name": "Newcomers' Guide",
            "url": "https://twisty-sign-c8b.notion.site/Guide-for-Greeks-live-X-Deribit-Newbies-5a08a3052822427d800af6eaf3704c8d"
        },
        {
            "@type": "WebSite",
            "name": "Knowledge Base",
            "url": "https://linktr.ee/greeks.live"
        },
        {
            "@type": "WebSite",
            "name": "Option Terminology",
            "url": "https://greekslive.notion.site/88dfc00e7c584d4d8969b6302a79a12f?pvs=4"
        },
        {
            "@type": "WebSite",
            "name": "Terms of Service",
            "url": "https://greeks.live/#/tos"
        },
        {
            "@type": "WebSite",
            "name": "Disclaimer",
            "url": "https://greeks.live/#/disclaimer"
        }
    ],
    "sameAs": [
        "https://x.com/greekslive",
        "https://youtube.com/@greeks_live?si=-KjT0Lkw4WUCI0tD",
        "https://t.me/greekslive_notifications",
        "https://t.me/greekslive",
        "https://pinterest.com/greekslive/"
    ],
    "makesOffer": [
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "RFQ Platform",
                "url": "https://rfq.greeks.live",
                "description": "Execute institutional-grade block trades for crypto options and futures. This platform provides deep, over-the-counter (OTC) liquidity via a professional Request for Quote system.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Lending Tools",
                "url": "https://lend.greeks.live",
                "description": "Manage crypto lending and borrowing activities to earn yield or secure loans. This suite of tools helps users analyze interest rates and manage collateralized debt positions.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Data Lab",
                "url": "https://greeks.live/#/deribit/tools/datalab/BTC",
                "description": "Analyze historical and real-time options data with advanced metrics. This tool is designed for backtesting strategies and identifying market trends through comprehensive data visualization.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Profit & Loss Analysis (PnL)",
                "url": "https://greeks.live/#/deribit/tools/pnl_analysis",
                "description": "Track and analyze the Profit and Loss (PnL) of your options portfolio. This tool provides detailed performance metrics to help traders evaluate and refine their strategies.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Position Visualization",
                "url": "https://greeks.live/#/deribit/tools/pv/BTC",
                "description": "Visualize complex options positions and their corresponding risk profiles. This tool generates payoff diagrams to help traders intuitively understand potential profit, loss, and exposure.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Options Calculator",
                "url": "https://greeks.live/#/deribit/tools/calculator",
                "description": "Calculate the theoretical price and risk parameters ('the Greeks') of crypto options. An essential tool for pricing new trades and analyzing the sensitivity of existing positions.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Greeks.live Main Platform",
                "url": "https://greeks.live/",
                "description": "The central hub for the Greeks.live suite of professional cryptocurrency options and derivatives trading tools. Access analytics, manage positions, and explore the ecosystem.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Community Forum",
                "url": "https://t.greeks.live",
                "description": "Join the official Greeks.live community. Connect with other traders, share insights, and receive the latest updates directly from the team.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Greeks.live for Deribit",
                "url": "http://deribit.greeks.live",
                "description": "A dedicated interface for trading on the Deribit exchange. This platform leverages Greeks.live's advanced analytics and tools specifically for users of Deribit's options and futures markets.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "Greeks.live for OKX",
                "url": "http://okx.greeks.live",
                "description": "A dedicated interface for trading on the OKX exchange. This platform integrates Greeks.live's powerful analytics with the OKX marketplace, focusing on its options and derivatives products.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "GLVS.AI Trading Platform",
                "url": "https://www.glvs.ai/",
                "description": "An AI-powered platform for automated crypto options trading. Leverage advanced algorithms and data-driven signals to develop and deploy sophisticated, hands-free trading strategies.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        },
        {
            "@type": "Offer",
            "itemOffered": {
                "@type": "Service",
                "name": "API Testnet & Sandbox",
                "url": "https://test.greeks.live",
                "description": "A dedicated testnet environment for developers to test their API integrations and automated trading strategies. This sandbox allows for full functionality testing without risking real funds.",
                "provider": {
                    "@id": "https://greeks.live/#organization"
                }
            }
        }
    ],
    "subOrganization": [
        {
            "@type": "Organization",
            "name": "GreeksLive HK Co., Limited",
            "email": "support@greeks.live",
            "telephone": "+852-56418949",
            "address": {
                "@type": "PostalAddress",
                "streetAddress": "Unit 11, 27/F, K. Wah Centre, 191 Java Road",
                "addressLocality": "Hong Kong",
                "addressRegion": "North Point",
                "addressCountry": "CN",
                "postalCode": "0000"
            },
            "geo": {
                "@type": "GeoCoordinates",
                "latitude": "22.2932357",
                "longitude": "114.2022026"
            },
            "image": "https://options.greeks.live/wp-content/uploads/2025/08/Wah-Centre-Hong-Kong.jpg"
        }
    ]
}
```

```json
{
    "@context": "https://schema.org",
    "@type": "Article",
    "mainEntityOfPage": {
        "@type": "WebPage",
        "@id": "https://options.greeks.live/question/how-does-the-uncitral-model-law-influence-cross-border-insolvency-cases-in-the-us/"
    },
    "headline": "How Does the UNCITRAL Model Law Influence Cross-Border Insolvency Cases in the US? \u25b4 Question",
    "description": "The UNCITRAL Model Law, via Chapter 15, provides a standardized protocol for U.S. courts to recognize and aid foreign insolvency proceedings. \u25b4 Question",
    "url": "https://options.greeks.live/question/how-does-the-uncitral-model-law-influence-cross-border-insolvency-cases-in-the-us/",
    "datePublished": "2025-08-17T02:51:18+00:00",
    "dateModified": "2025-08-17T02:51:19+00:00",
    "articleSection": [
        "Question"
    ],
    "author": {
        "@id": "https://greeks.live/#organization"
    },
    "publisher": {
        "@id": "https://greeks.live/#organization"
    },
    "image": {
        "@type": "ImageObject",
        "url": "https://options.greeks.live/wp-content/uploads/2025/08/institutional-grade-digital-asset-derivatives-trading-platform-powering-high-fidelity-execution-via-advanced-rfq-protocol-prime-os-intelligence-layer.jpg",
        "caption": "This abstract system visualizes a Principal's Operational Framework for Institutional Digital Asset Derivatives. Its multi-layered architecture, with integrated Intelligence Layer and circuit pathways, signifies a robust Prime RFQ enabling Private Quotation and Aggregated Inquiry via RFQ Protocol. The design emphasizes High-Fidelity Execution, minimizing Slippage and Latency through Smart Order Routing, supporting complex Multi-Leg Spread strategies and Portfolio Margin for optimal Capital Efficiency."
    },
    "keywords": [
        "Automatic Stay",
        "Bankruptcy Code",
        "Chapter 15 Bankruptcy",
        "Cross-Border Insolvency",
        "Foreign Main Proceeding",
        "Foreign Representative",
        "International Comity",
        "Permissive Relief",
        "Recognition Order",
        "U.S. Bankruptcy Code",
        "UNCITRAL Model Law"
    ]
}
```

```json
{
    "@context": "https://schema.org",
    "@type": "WebSite",
    "url": "https://options.greeks.live/",
    "potentialAction": {
        "@type": "SearchAction",
        "target": "https://options.greeks.live/?s=search_term_string",
        "query-input": "required name=search_term_string"
    }
}
```


---

**Original URL:** https://options.greeks.live/question/how-does-the-uncitral-model-law-influence-cross-border-insolvency-cases-in-the-us/
