The European Union approach to cross border insolvencies. The European Insolvency Regulation.

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…optional clause whereby special insolvency regimes applicable to, for instance, banks or insurance companies may be excluded from its scope. 6. Conclusion: The EU Regulation only has limited provisions of substantive law. Also, the universal approach (within the EU) of the EU Regulation can be limited in case of secondary proceedings (if there is an establishment in another Member State). Therefore, in my opinion the UNCITRAL Model Law is the best solution for cross border insolvency.