Case Reference: #2024-MULTI-0012

Client profile: US-based industrial components manufacturer specialising in hydraulic systems for mining and construction equipment. Annual revenue $85M. Operations in 14 countries.

Total claim: $2,100,000 across three debtors in three jurisdictions.

The situation

The manufacturer's CFO contacted us with a portfolio problem, not a single-claim problem. Three significant receivables had aged beyond 120 days simultaneously, each in a different jurisdiction with different enforcement landscapes:

Debtor 1 — Germany: €580,000 owed by a German mining equipment manufacturer in Essen. The debtor had filed a Widerspruch against an earlier Mahnbescheid obtained by the manufacturer's German lawyer, and the case was languishing in pre-trial proceedings.

Debtor 2 — Brazil: $920,000 owed by a Brazilian construction equipment distributor in São Paulo. The distributor had been a reliable partner for three years before payments stopped. Communication had ceased entirely.

Debtor 3 — Saudi Arabia: $600,000 owed by a Saudi Arabian mining contractor based in Riyadh. The contractor was a government-adjacent entity with connections to Saudi Aramco's supply chain. The manufacturer's regional sales director advised against aggressive enforcement, citing relationship concerns.

The coordination strategy

Recovering across three continents requires more than filing in three jurisdictions. It requires a coordinated timeline that creates simultaneous pressure on all three debtors — and, critically, creates the perception within the manufacturer's debtor portfolio that enforcement is now institutional rather than ad hoc.

Germany: Our Frankfurt team reviewed the stalled litigation file and identified that the manufacturer's previous counsel had not pre-empted the debtor's set-off claim with contemporaneous evidence. We re-filed with a comprehensive evidence package including timestamped delivery confirmations, acceptance protocols, and the debtor's own quality approval emails. The Landgericht Essen scheduled a Güteverhandlung within six weeks.

Brazil: Our São Paulo correspondent team initiated an ação de cobrança (collection action) through the Tribunal de Justiça de São Paulo and simultaneously filed for a penhora online (electronic seizure) through the BACENJUD system — Brazil's electronic judicial attachment system that freezes bank accounts across all Brazilian financial institutions within 24 hours. The penhora online captured R$1.8 million (approximately $350,000) in the distributor's accounts at Banco do Brasil and Itaú.

Saudi Arabia: Our Riyadh-based counsel filed a claim with the Saudi Commercial Court (al-mahkama al-tijariyya) under the Saudi Enforcement Law (Royal Decree M/53). The filing was accompanied by a formal demand through the Saudi Execution Court, which has the authority to impose travel bans and freeze assets. The filing was respectful, procedurally precise, and framed as a commercial matter — not a relationship dispute.

Resolution

Germany: At the Güteverhandlung, the judge indicated that the debtor's set-off claim was "not supported by the documentary record." Settlement was reached: €580,000 paid in full within 30 days. Timeline: 58 days.

Brazil: The distributor's advogado contacted our São Paulo team within 48 hours of the penhora online. Settlement was reached: $920,000 paid in three instalments over 90 days, secured by a nota promissória (promissory note) that constitutes an independent enforcement title under Brazilian law. Timeline: 14 days to settlement agreement, 90 days to completion.

Saudi Arabia: The Saudi contractor's representative contacted our Riyadh counsel within 10 days of the Execution Court filing. Payment of $600,000 was arranged through an escrow account within 28 days. The manufacturer's regional sales director reported that the relationship was preserved — the contractor expressed respect for the "professional" approach and continued placing orders.

Total recovered: $2,100,000 — 100% of the aggregate claim. Aggregate timeline: 90 days from engagement to final payment.

The multi-jurisdiction intelligence note

Coordinated multi-jurisdiction recovery produces results that sequential recovery cannot. The manufacturer's previous approach — engaging local counsel separately in each jurisdiction, with no coordination and no shared timeline — had produced one stalled German litigation and two ageing receivables. The coordinated approach produced full recovery in 90 days.

The coordination advantage is not just operational. It's informational. When a debtor's CFO receives simultaneous enforcement actions across multiple jurisdictions, they recognise that the creditor has moved from bilateral negotiation to institutional enforcement. The psychological shift changes the debtor's calculation from "how long can I delay?" to "how quickly can I settle?"

If you're holding receivables across multiple jurisdictions and managing them separately, you're giving each debtor the luxury of individual negotiation. Brief our multi-jurisdiction coordination team to create simultaneous enforcement pressure.