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Lead Counsel for Multi-Jurisdictional Transactions
Ask a firm in Germany about German law and the answer will be correct. Ask four firms in four jurisdictions and you get four correct answers, none of which were written to fit together.
The legal work that decides the outcome sits above them. Where do two regimes genuinely conflict, as opposed to merely differ. Which jurisdiction’s law should govern which piece. What has to change in the structure so the position holds everywhere it needs to hold. Which of those four answers is actually load-bearing for the deal, and which only looks urgent.
That work does not belong to any of the four firms. It belongs to lead counsel. Here is how we run the matter.
The Lead Counsel model
Transaction structuring across jurisdictions
Before anyone is instructed locally, we decide what the deal needs to look like to work as a whole. This is transactional and corporate work done with every jurisdiction in view at once.
Conflict of laws analysis
We identify where two legal regimes genuinely conflict, as opposed to merely differ, and determine what the structure has to do about it.
Instructing and managing local counsel
Narrow, specific questions scoped to what each jurisdiction’s law actually determines. Your existing firms, or ours.
A single reconciled legal position
One answer rather than four memos. Where local counsel disagree, we resolve it rather than forwarding it.
Negotiation, documentation and closing
Global Link Law is counsel on the matter, at the table, through signing and completion.
What Goes Wrong on a Multi-Jurisdictional Deal
Four right answers, one wrong structure
Local counsel answers local questions well. Ask four firms in four jurisdictions and you get four correct answers, none of which were written to fit together.
No one owns the transaction as a whole
Each firm is accountable for its own jurisdiction. The structure that has to hold across all of them belongs to no one on the current roster.
Conflicts surface late, when they are expensive
Most apparent conflicts between legal regimes are differences that can be drafted around. The genuine ones drive the structure, and finding them after signing costs far more than finding them before. Where a dispute has already started, our litigation team works from the same reading of the deal.
Your in-house team becomes the integration layer
Legal departments end up reconciling memos, chasing timelines and translating between firms. That is not the work they were hired to do. Where the gap is capacity rather than coordination, our fractional general counsel model may be the better fit.
Ideal For
Companies Acquiring or Investing Across Borders
A transaction with parties, assets or regulators in more than one country, and no single firm currently holding the whole of it.
In-House Teams Coordinating Multiple Firms
A legal department already paying for local advice in several jurisdictions and spending its own time stitching the answers together.
Companies Entering a New Jurisdiction
Market entry where the structure, the contracts and the regulatory position all need to be decided together rather than in sequence.
Transactions That Have Begun to Drift
A deal where the jurisdictions have started pulling in different directions and someone needs to take hold of it.
How We Run the Matter
Engagement Type
Project BasedBefore anyone is instructed locally, we decide what the deal needs to look like to work as a whole.
We identify where two legal regimes genuinely conflict, as opposed to merely differ, and determine what the structure has to do about it.
Narrow, specific questions scoped to what each jurisdiction’s law actually determines. Your existing firms, or ours.
One answer rather than four memos. Where local counsel disagree, we resolve it rather than forwarding it.
Global Link Law is counsel on the matter, at the table, through signing and completion.
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Global Link Law
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