Cross-border insolvency

In international practice, the key idea of cross-border insolvency legislature is to recognize the bankruptcy process at the location of the debtor’s basic vital interests as the main one, and to coordinate actions in other jurisdictions with this main process.
Cross-border insolvency is regulated by the model law of the UNCITRAL On Cross-Border Insolvency adopted by the UN in 1997. It applies if other is not provided by bilateral agreements between countries. As at March 3, 2022, legislature based on the UNCITRAL model law On Cross-Border Insolvency is adopted in 50 countries.

Application procedure on recognition of foreign insolvency in Israel

Notarized and apostilled application from financial manager in the Russian Federation, which describes the bankruptcy procedure in Russia and states all known foreign bankruptcy procedures against the debtor (if any)
A power of attorney to the representative to conduct the process of bankruptcy and realization of the debtor’s property/assets
Apostilled copy of the decision of a foreign relevant authority (arbitration court) initiating a bankruptcy procedure and appointing the applicant as the financial manager

Stages of recognition of foreign insolvency in Israel

Stage 1. Recognition of foreign insolvency in Israel and conduction of official investigation:
- Filing application on recognition of foreign insolvency in Israel –
14 days after obtaining the required documents from the financial manager

- Recognition of foreign insolvency – 30-45 days after filing the application

Conduction of official investigation and search for the debtor’s assets in Israel. A comprehensive written report is provided within 60-90 days after recognition of insolvency
Stage 2. Combined analysis of expediency to continue the case and realization of the debtor’s assets:
- The creditors are entitled to make a decision to continue the bankruptcy procedure in Israel or to close the case

- In case the debtor’s property is found and the bankruptcy procedure continues, activities on realization of the debtor’s property are conducted

The duration of realization of property in Israel:
from 6 to 36 months