International debt recovery has a reputation problem. Creditors assume that pursuing a debtor across borders involves prohibitive legal costs, years of court proceedings, and uncertain outcomes. The debtor's advisors reinforce this assumption — sometimes explicitly, sometimes simply by failing to respond to demand letters and allowing the creditor to conclude that enforcement is impractical.

The assumption was accurate twenty years ago. It is not accurate now. Cross-border enforcement instruments have expanded significantly over the past decade, and the jurisdictions that process the most international trade have modernised their recognition and enforcement procedures accordingly. The gap between the creditor's perception and the enforcement reality is the debtor's most valuable asset. Here are five instruments that close that gap.

1. The New York Convention makes arbitral awards enforceable in 172 countries

The Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958) has 172 signatory states. An arbitral award obtained under the Convention is enforceable in any signatory state through a recognition proceeding that is procedural, not substantive — the enforcement court does not re-examine the merits of the dispute.

For creditors whose contracts contain arbitration clauses (and most international commercial contracts do), this means that an award obtained in London, Paris, Singapore, or any other arbitration seat is enforceable against the debtor's assets wherever they are located — provided the assets are in a Convention signatory state. The recognition proceeding typically takes two to six months, depending on the jurisdiction.

The practical implication: a debtor who refuses to pay an arbitral award cannot hide behind jurisdictional complexity. The creditor can pursue enforcement wherever the debtor's assets are located, and the debtor's only defence is one of the narrow grounds for refusal set out in Article V of the Convention.

2. The European Account Preservation Order freezes accounts across 25 EU states

EU Regulation 655/2014 created the EAPO, which allows creditors to freeze bank accounts in any EU member state (except Denmark) before or after obtaining a judgment. The order is obtained from a court in the creditor's home jurisdiction and executed directly in the debtor's jurisdiction without a separate recognition proceeding.

The EAPO is particularly effective against debtors who maintain accounts in multiple EU states. A single EAPO can target accounts in multiple jurisdictions simultaneously, and the debtor is not notified until the freeze is executed.

3. The Hague Judgments Convention is expanding recognition networks

The Hague Convention on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters (2019) is gradually expanding the network of countries where court judgments — not just arbitral awards — are enforceable across borders. As more countries ratify the Convention, the enforcement landscape for creditors holding court judgments rather than arbitral awards will improve significantly.

For creditors with existing court judgments, bilateral and multilateral enforcement agreements already provide recognition pathways in many jurisdictions. The key is identifying which agreements apply between the judgment country and the enforcement country — a mapping exercise that determines whether enforcement is practical before the creditor invests in the recognition proceeding.

4. Electronic seizure systems make bank account freezes instant in major jurisdictions

Brazil's BACENJUD, Poland's EPU-connected enforcement system, and France's FICOBA-enabled saisie-attribution all provide electronic mechanisms for identifying and freezing debtor bank accounts. These systems reduce the enforcement timeline from weeks to hours — and they eliminate the debtor's ability to move funds between accounts once the creditor has an enforceable title.

For creditors pursuing enforcement in jurisdictions with electronic seizure systems, the practical effect is that obtaining the enforceable title is the hard part. Execution is fast, digital, and comprehensive.

5. Coordinated multi-jurisdiction filing changes the debtor's calculation

The most powerful cross-border enforcement tool isn't a legal instrument. It's a strategy. Filing simultaneously in multiple jurisdictions — with coordinated local counsel and a shared enforcement timeline — creates pressure that sequential filing cannot replicate.

A debtor managing one enforcement action in one jurisdiction has bandwidth to delay, negotiate, and manoeuvre. A debtor facing simultaneous enforcement actions in three or four jurisdictions has a different calculation: the cost of defending across multiple fronts exceeds the cost of settling.

We deploy coordinated multi-jurisdiction filings for clients whose debtors operate across borders. The approach requires investment in local counsel relationships and enforcement infrastructure, but it produces results that justify the investment — typically within 60-90 days.

If your international debtor is relying on your assumption that cross-border enforcement is impractical, they're relying on outdated information. Brief our international enforcement team to assess which instruments apply to your specific claim and jurisdiction.