Comparative Guide to Restructuring Procedures in the UK, US, DIFC, ADGM and UAE

January 12, 2021

We are pleased to present a comparative guide to restructuring procedures in the UK, US, DIFC, ADGM and UAE.

The easy-to-use comparative guide is organised by key aspects of the restructuring processes and compares and contrasts the selected restructuring regimes in each jurisdiction so that the reader can easily identify the differences.

The comparative guide will be particularly relevant for clients operating in the UAE who may be considering restructuring options in the current market conditions.

Comparative Guide to Restructuring Procedures in the UK, US, DIFC, ADGM and UAE


For further information, please contact the Gibson Dunn lawyer with whom you usually work, or the following authors, with any questions, thoughts or comments arising from this update.

Aly Kassam – Dubai (+971 (0) 4 318 4641, [email protected])
Scott J. Greenberg – New York (+1 212-351-5298, [email protected])
David M. Feldman – New York (+1 212-351-2366, [email protected])
Ben Myers – London (+44 (0) 20 7071 4277, [email protected])
Galadia Constantinou – Dubai (+971 (0) 4 318 4663, [email protected])
Ashtyn Hemendinger – New York (+1 212-351-2349, [email protected])

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Gibson Dunn’s Middle East practice focuses on regional and global multijurisdictional transactions and disputes whilst also acting on matters relating to financial and investment regulation. Our lawyers, a number of whom have spent many years in the region, have the experience and expertise to handle the most complex and innovative deals and disputes across different sectors, disciplines and jurisdictions throughout the Middle East and Africa.

Our corporate team is a market leader in MENA mergers and acquisitions as well as private equity transactions, having been instructed on many of the region’s highest-profile buy-side and sell-side transactions for corporates, sovereigns and the most active regional private equity funds. In addition, we have a vibrant finance practice, representing both lenders and borrowers, covering the full range of financial products including acquisition finance, structured finance, asset-based finance and Islamic finance. We have the region’s leading fund formation practice, successfully raising capital for our clients in a difficult fundraising environment.

Our international Business Restructuring and Reorganization Practice is a leader in U.S., European, Middle East and cross-border insolvencies and workouts. Our lawyers advise companies in financial distress, their creditors and investors, and parties interested in acquiring assets from companies in distress. We also guide hedge funds, private equity firms and financial institutions investing in distressed debt and/or equity through the restructuring and bankruptcy process. The group has been widely recognized by top industry publications, including Chambers and The Guide to the World’s Leading Insolvency Lawyers. Our lawyers are committed to understanding the businesses of their clients and crafting solutions, including complex out-of-court workouts and in-court restructurings. We also advise on innovative DIP and exit financing agreements to both debtors and DIP providers.