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Noah D’Aeth

Associate
Noah D’Aeth is an associate at Cleary Gottlieb Steen & Hamilton LLP, specialising in UK financial services regulation. Email: ndaeth@cgsh.com

Articles by author

Loan participations: conflict-of-laws challenges under English and New York law

This article examines the divergent treatment of loan participations under English and New York law, focussing on how each jurisdiction characterises the legal relationship between grantor and participant. It explores the conflict-of-laws challenges that arise when structuring cross-border financing transactions in which the underlying loan and participation agreement may be governed by different legal systems.

22 NOV 2025