Recognition and Assistance of Foreign Insolvency Proceedings: A Comparison of Singapore’s Model Law Regime with the Approaches of the BVI, Cayman and Bermuda Courts

Exploring Offshore Litigation · Oct 17, 2025 · 1m

In 2017, Singapore incorporated the UNCITRAL Model Law on Cross-Border Insolvency (the 'Model Law') into its domestic legislation,1 providing a comprehensive and structured framework for the recognition and assistance of foreign corporate insolvency proceedings. By contrast, the offshore jurisdictions of the British Virgin Islands, the Cayman Islands, and Bermuda have not adopted the Model Law. Each relies on its own domestic statutory mechanisms and common law principles. The Singapore Model Law regime thus provides a useful reference point against which to examine the more varied approaches…