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Navigating Insolvency Issues In The EU:German, French, UK, and American Perspectives 1I. IntroductionA. The insolvency of a company has a significant impact on the insolventcompany’s customers, vendors, suppliers, lenders, landlords, tenants, and otherparties to the company’s contracts. A creditor of an insolvent company has enoughproblems when the bankruptcy or insolvency proceeding has been filed in the samecountry in which the creditor operates. When the bankruptcy or insolvencyproceeding is pending in another country, the creditor’s problems are multiplied.B. The increasing level of international trade has led to greater use ofcross-border insolvency proceedings in the European Union. Recent developmentsin international law may have made the use of insolvency proceedings as a businesstool more common. Currently, the laws for dealing with insolvency vary from countryto country within the EU and, indeed, from country to country around the world.II.Insolvency law not unified in EUA. The United Nations Commission on International TradeLaw (UNCITRAL) adopted its Model Law on Cross-Border InsolvencyIn 1997, the United Nations Commission on International Trade Law (UNCITRAL)adopted its Model Law on Cross-Border Insolvency to help national legislatures draft1 Materials prepared by John Roberts of the ALFA Baltimore, Maryland firm Semmes, Bowen, and Semmes, PC,and John Sykes of the ALFA London, England firm of Charles Russell, LLP.2