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Cross-border commercial disputes

When the dispute, like the deal, crosses a border.

Commercial disputes involving a foreign investor, a counterparty abroad, or a contract under another law, where the first questions are jurisdiction, governing law, and enforceability.

A cross-border dispute is decided in part before the merits are reached. Which court has jurisdiction, which country's law governs, where a judgment can actually be enforced, and how a foreign party is served and bound, all shape the outcome. The firm, working in English, Hebrew, and Arabic, runs these for foreign investors operating in Israel and for Israeli businesses facing a counterparty abroad.

The work spans
  • Jurisdiction and forum disputes, including jurisdiction clauses and competing proceedings.
  • Governing-law questions where the contract points to a foreign system.
  • Service on, and enforcement against, parties and assets outside Israel.
  • Recognition and enforcement of foreign judgments in Israel, and of Israeli judgments abroad.
  • Provisional relief to secure assets across jurisdictions while the dispute proceeds.
  • A foreign counterparty has breached and you need to know where, and under which law, to pursue it.
  • You are a foreign investor in a dispute with an Israeli party and need counsel on the ground.
  • A jurisdiction or governing-law clause is being used to push the dispute into an unfavourable forum.
  • You hold or face a foreign judgment that now has to be enforced or resisted in Israel.

The firm settles the architecture before the argument: jurisdiction, governing law, and the enforcement target are decided first, because they determine whether a win is collectable. It coordinates with local counsel where assets or proceedings sit abroad, and it builds the case for the forum it will actually be heard in. It plans enforcement from the outset, not after judgment.

04 · What you get

Architecture first

Jurisdiction, law, and enforcement target decided before the merits are argued.

A collectable result

The case is run toward the place where the assets actually are.

One trilingual team

English, Hebrew, and Arabic, coordinating local counsel where needed.

An Israeli business and a foreign counterparty fall into dispute under a contract that points to a foreign governing law. The firm contests the forum, fixes which law governs, and aligns the case with an enforcement plan directed at the jurisdiction where the counterparty holds assets.

Described in abbreviated, anonymised form to preserve client confidentiality.

Where is a cross-border commercial dispute litigated?

It depends on any jurisdiction clause, on where the parties and the harm are, and on where a judgment could be enforced; the forum question is often the first and most consequential fight in a cross-border case.

Which country's law governs our contract?

Usually the law the contract chooses, and absent a choice, the law with the closest connection to the contract; the answer can change the result, so it is resolved early.

Can a foreign judgment be enforced in Israel?

Generally yes, through the recognition-and- enforcement framework for foreign judgments, subject to defined conditions and defences, which is why enforcement is planned from the start rather than assumed.

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