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Cross-border security releases: navigating the patchwork of local law requirements
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This article examines the principal considerations that ought to inform the chosen approach, with particular reference to the distinction between accessory and non-accessory security regimes. It gives close attention to French law – where the accessory nature of sûretés réelles means that a mainlevée (a formal release) serves primarily to update public registers and to render the discharge binding on and enforceable against third parties (as non-signatories) – and contrasts the position with that under English law. The article proposes a framework for deciding when a consolidated release is feasible, when it is not, and how to manage the interface between English law deeds and foreign law discharge formalities.
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