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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. We run it as a defined sequence, the Global Link Law Lead Counsel Model, in five stages.
The Model
The Global Link Law Lead Counsel Model
Local counsel answer local questions. One firm decides the structure those answers have to fit, and carries a single position to close.
Stage one · Structure
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.
Output
A transaction structure decided as one design, before a single local firm is instructed.
Stage two · Conflicts
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.
Output
A short list of the conflicts that are real, and what the structure does about each one.
Stage three · Instruction
Instructing and managing local counsel
Narrow, specific questions scoped to what each jurisdiction’s law actually determines. Your existing firms, or ours.
Output
A scoped question to each jurisdiction, and the answer it was actually asked for.
Stage four · Reconciliation
A single reconciled legal position
One answer rather than four memos. Where local counsel disagree, we resolve it rather than forwarding it.
Output
One position you can sign, rather than four memos you have to weigh.
Stage five · Execution
Negotiation, documentation and closing
Global Link Law is counsel on the matter, at the table, through signing and completion.
Output
The transaction negotiated, papered and closed by the counsel who structured it.
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.
One Structure, Decided First
We decide how the transaction should be structured across every jurisdiction it touches before any local firm is instructed, so the answers that come back were written to fit one design rather than four.
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.
Lead Counsel on the Whole Matter
We take the transaction as a single matter rather than a set of local questions, hold the structure across every jurisdiction, and stay accountable for it from the first instruction through closing.
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.
Conflict of Laws Analysis
We find early where two legal regimes genuinely conflict rather than merely differ, and settle in the structure what each real conflict requires, while the cost of changing it is still low.
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.
One Reconciled Position
We scope the narrow question each jurisdiction actually answers, reconcile what comes back into a single position you can sign, and hand your team a decision rather than four memos to weigh.
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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