SECTOR INTELLIGENCE / ENERGY
Energy and commodity debt collection involves the highest values, the most complex corporate structures, and the most creative jurisdiction shopping we encounter. Trading houses, SPVs, force majeure claims, FX complications, and debtors whose legal teams outnumber their operational staff. We match them.
WHY ENERGY DEBT IS DIFFERENT
An energy trading house in Geneva bills through a Singapore subsidiary, insured through a Bermuda captive, with the physical cargo delivered by a Liberian-flagged vessel to a Nigerian port. The debtor's operating entity has minimal assets. The holding company has all of them. Piercing this structure requires forensic corporate analysis.
Energy debts routinely exceed USD 500,000 and frequently reach into the millions. At these values, debtors invest in legal resistance. Their in-house counsel is prepared. Their corporate structure is defensive by design. Collection requires matching their legal sophistication.
Energy debtors invoke force majeure more than any other sector. Sanctions, embargoes, pipeline disruptions, port closures, price collapses — all cited as reasons not to pay. We assess each claim against the contract's force majeure clause and the actual market conditions. Most do not qualify.
USD-denominated contracts with BRL, NGN, or AED payment obligations create FX conversion disputes. Central bank restrictions in some jurisdictions require specific payment pathways. We identify legitimate payment channels and counter the debtor's claim that 'we cannot transfer the funds.'
HOW WE HANDLE ENERGY CASES
We map the debtor's entire corporate group — parent, subsidiaries, SPVs, holding companies, nominee directors — and identify where the assets and the contractual obligations actually sit. The entity that signed the contract is often not the entity with the money.
Energy cases frequently involve simultaneous action in multiple jurisdictions — freezing assets in one country while pursuing the claim in another. We coordinate across jurisdictions with a unified strategy, not isolated local actions.
Many energy contracts contain ICC or LCIA arbitration clauses. We manage the arbitration process and, critically, the enforcement of the award — which often requires proceedings in the jurisdiction where the debtor's assets are located.
JURISDICTION FOCUS
Energy debt follows commodity flows and trading hub locations. Switzerland (Geneva — the world's commodity trading capital), UAE (Dubai — oil, gas, and metals trading), Nigeria (Africa's largest oil producer), and Brazil (offshore oil and biofuels) are our most active energy jurisdictions. Each has different enforcement mechanisms, arbitration frameworks, and FX regulations — and we operate natively in all four.
DECLASSIFIED | ENERGY | CH → NG
InterStation's team identified that the debtor maintained USD-denominated accounts in both Lagos and Dubai. The "FX restriction" applied to Naira conversion — not to existing USD holdings. Filed simultaneously: garnishee proceedings in Lagos + precautionary attachment in Dubai. 85% collected in 72 days.
"The FX restriction was real. The excuse was not. They had USD in two countries."
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