Cross-Border Case Studies
Representative engagements across Europe and Latin America — where sponsors, collateral, and capital spanned jurisdictions, and our regional teams coordinated the structure from end to end.
Deals Across Two Continents
These engagements illustrate how European and Latin American sponsors have secured structured capital across borders — coordinating collateral, security, and capital partners across multiple jurisdictions simultaneously.
Our Approach to Discretion
Confidentiality is foundational to our firm. The scenarios below are representative composites drawn from real engagements — identifying details have been intentionally generalized. Each mandate is conducted under strict non-disclosure, on a relationship-managed basis. We never disclose client names, holdings, or transaction specifics.
Client 01
Swiss Family Office
Zurich · London
Multi-generational European family office holding €60M across SIX-listed equities, Euronext blue chips, and German bunds, seeking to fund a private acquisition.
Challenge
Needed €18M to acquire a controlling stake in a private European business without liquidating a diversified public portfolio spanning Swiss, French, and German exchanges.
Solution
Originated a blended-collateral facility with a London-based capital partner, sized against SIX, Euronext, and Xetra haircuts, documented under English law with security perfected across three EU jurisdictions.
Outcome
Facility closed in three weeks with security perfected simultaneously in Switzerland, France, and Germany. The family retained full ownership and dividend income across the pledged portfolio.
Client 02
Brazilian Agribusiness Principal
São Paulo · New York
Founding family of a Brazilian agribusiness group with B3-listed and ADR holdings seeking cross-border USD liquidity.
Challenge
Required $22M in USD liquidity to fund an international expansion, but Brazilian capital controls and B3 collateral conventions made a domestic facility inefficient.
Solution
Originated a cross-border facility with a US capital partner, drawing in USD against a blended pool of B3-listed equities and NYSE-listed ADRs, structured around Brazilian capital-control and currency regulations.
Outcome
USD facility funded within four weeks without triggering a taxable domestic sale. The structure respected local capital controls while giving the family clean USD liquidity for the expansion.
Client 03
Pan-European Founder
London · Zurich · Paris
Technology founder with holdings concentrated in LSE and Euronext-listed equities, planning a cross-border real-estate purchase.
Challenge
Needed £9M against a concentrated, cross-listed equity position to fund a real-estate acquisition, without a forced sale that would crystallise significant gains.
Solution
Originated a share-backed facility with a European capital partner at 60% LTV, structured with an equity collar to protect against downside on the concentrated position, documented under English law.
Outcome
Facility funded in 18 days. The collar protected the position through a subsequent market drawdown, and the founder completed the real-estate purchase while retaining upside within the agreed range.
Client 04
Mexican Family Group
Mexico City · Houston
Mexican industrial family group with diversified LatAm and US-listed holdings seeking acquisition financing.
Challenge
Sought $15M to acquire a US-based distribution business, but the family’s collateral sat across Mexican, Brazilian, and US exchanges with no single lender willing to take the blended pool.
Solution
Originated a cross-border repo facility with a US counterparty, funding drawn in USD against a blended collateral pool spanning BMV, B3, and NYSE-listed securities, with title transfer under a GMRA framework.
Outcome
The blended-pool repo funded in two weeks, giving the family USD acquisition capital against collateral no single domestic lender would accept. Substitution rights preserved portfolio flexibility.
Case studies are illustrative and based on composite engagements. Individual results vary. Figures shown are for informational purposes and do not constitute investment advice or a guarantee of future results.
The Frictions We Coordinate Away
A domestic facility is a single-lender, single-jurisdiction exercise. A cross-border one is four transactions stitched into one — security in every jurisdiction, collateral across exchanges, currency where the sponsor actually needs it, and documentation that survives a default in any of them. These are the frictions that make cross-border structured origination a specialist discipline.
Jurisdictional Security Perfection
Pledging collateral across borders means perfecting security in each jurisdiction where the securities sit. Each country has its own registry, custodian chain, and perfection formalities — English law security over Swiss, French, and German assets requires coordinated perfection in all three simultaneously to avoid gaps that a lender will not accept.
Capital Controls & Currency
Brazil, Argentina, and other LatAm jurisdictions impose capital controls and FX regulations that can trap collateral or restrict cross-border flows. Structures must be engineered around the rules — drawing in USD against ADRs or structuring repo title transfers to avoid triggering a restricted domestic sale.
Blended Collateral Haircuts
No single domestic lender wants a pool spanning BMV, B3, SIX, Euronext, and NYSE. Each exchange has its own liquidity, volatility, and settlement conventions that drive different haircuts. A blended facility requires modelling an aggregate LTV that accounts for cross-exchange concentration and settlement mismatch risk.
Downside & Concentration Risk
A concentrated cross-listed position carries single-name and currency risk. Equity collars, puts, and substitution rights are used to protect against drawdown without forcing a sale — especially important where a crystallising gain would create a tax event across two tax regimes.
Europe
Jurisdictional Considerations
Switzerland (SIX)
Swiss pledge perfection via intermediary custodian; no public filing for most security. Bank secrecy and FINMA considerations shape documentation.
United Kingdom (LSE)
English law is the default documentation standard for European facilities. Security over book-entry securities perfected through the custodian/account controller.
France & Germany (Euronext / Xetra)
EU Financial Collateral Directive applies — streamlined perfection for financial collateral, but local notarial and language requirements remain.
Latin America
Jurisdictional Considerations
Brazil (B3)
B3-listed collateral is pledgeable but subject to BACEN capital-control reporting. USD draws typically route through ADRs or offshore structures to respect FX rules.
Mexico (BMV)
BMV securities can secure cross-border repos under GMRA-style title transfer; INBV and local custodian chain must be coordinated for clean perfection.
Cross-Currency Draws
LatAm sponsors often need USD liquidity against local-currency collateral. Repo or VPFS structures convert exposure without a taxable domestic sale.
The Structures We Apply
Each structure is chosen for how it handles the specific friction above — security, currency, concentration, or committed capital.
Share-Backed Financing
Blended pools across SIX, Euronext, Xetra, LSE; coordinated perfection under English law.
ExploreCross-Border Repos
GMRA-style title transfer across BMV, B3, and NYSE; USD draws against local-currency collateral.
ExploreVPFS
Monetise a concentrated cross-listed position with a built-in floor, deferring a cross-border taxable sale.
ExploreEquity Commitments / PIPEs
Committed capital for issuers on LatAm and European exchanges requiring reliable, pre-agreed draw capacity.
ExploreHave a Cross-Border Opportunity?
If your transaction spans Europe, Latin America, or any combination of jurisdictions, we would welcome a confidential introduction. Our regional teams will coordinate the structure.
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