Jurisdiction
United States: investor claims and enforcement
The United States holds private capital that never touched a public exchange: venture rounds, real estate syndications, arbitration clauses buried inside subscription agreements. When a counterparty stops paying, the live question is which state's rules apply, and whether the underlying instrument was a judgment or an arbitral award. See how this compares with other jurisdictions we track.
Recognition in and out
The US has not ratified the 2019 Hague Judgments Convention, so no treaty route carries a foreign judgment into a US court; recognition runs through state law. Mechanics for bringing a claim in are set out for enforcement of a foreign judgment in the US and, for one pair, enforcement from the UK into the US. Arbitration travels a steadier path: a foreign award has three years from the date it was made, though the Second and D.C. Circuits disagree on what happens once that window closes. Judgment recognition then depends on the state: New York allows the shorter of home-country validity or twenty years and a summary judgment procedure; Delaware allows fifteen years where the origin sets none; California allows the shorter of ten years or home validity, and sits outside the usual state framework for enforcing foreign judgments. Filing fees are fixed sums regardless of claim size, and apostilled documents have been accepted since 15 October 1981.
Asset classes that concentrate here
Venture equity, private credit, and real estate syndications concentrate in the US because the paperwork is familiar to global investors: SAFE notes, LP agreements, and subscription documents drafted under Delaware or New York law. Many of these agreements carry an arbitration clause, and the clause itself often decides whether a later dispute follows the award-enforcement path rather than court litigation, a distinction covered in the clause behind stopped payments.
Digital-asset vehicles structured as Delaware entities are common for the same reason, even when the fund's actual operations sit elsewhere, a pattern that recurs when comparing the US to civil-law venues such as Italy.
What to secure early
Before a counterparty is put on notice, gather the signed agreement, every amendment, and any arbitration or forum clause in its original executed form. If the claim rests on an arbitral award, keep the award itself and proof of service; the three-year clock starts on the date of the award, regardless of when non-payment became clear. The approach to that first notice matters, as set out in drafting a first demand letter.
Confirm the counterparty's exact legal name and state of formation against public filings, and start tracing where its assets actually sit, a process described in tracing money after payments stop. Whether an interim measure can preserve those assets depends on the specifics of the case and the state involved.
Working with local counsel
Recognition and enforcement in US courts require counsel admitted in the specific state where the assets are located. We coordinate the claim ourselves and instruct that local counsel; we do not appear directly in a state where we hold no admission.
Legal fees are not published; only the cost of a paid initial assessment is. We do not work on a result-only fee, and how to check that against a public registry entry for the entity you're dealing with is worth doing before engaging anyone in this space.