ABSTRACT
International initiatives aimed at providing frameworks for cross-border insolvency are also usually lacking explicit consideration of the matter of enterprise groups. The EC Regulation on Insolvency Proceedings5 does not attempt to deal with the issue of groups.6 Similarly, the UNCITRAL Model Law on CrossBorder Insolvency7 deals with single debtors, not with groups. An exception is the American Law Institute (ALI) Principles of Cooperation8 which, although bounding their scope to a limited number of legal issues, do explicitly provide a couple of principles addressing the matter.9
