Lien Integrity Failures in Cross-Border Secured Structures.
Common perfection gaps that undermine senior-secured claims in enforcement.
We reviewed the enforcement outcomes of 28 cross-border secured bond defaults across the Nordics, the UK, the Netherlands and Luxembourg between 2019 and 2025.
In 11 of the 28 cases, senior-secured creditors recovered less than expected because of perfection gaps — most commonly missing local-law security confirmations after intra-group reorganisations.
The note categorises the gaps into five recurring patterns and proposes an annual lien-integrity attestation that trustees can request from issuers without amending the underlying security documents.
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