Landmark Cross-Border Insolvency Ruling: Bahrain Recognises Singaporean Liquidation Proceedings

In a landmark legal achievement, Al Doseri Law – under the leadership of lawyer Saad Al Doseri, acting as Bahraini legal counsel, and in coordination with the international law firm DLA Piper – led by partner Jared Green and associate Daniel Huang in Singapore, and partner Peter Somekh and legal director Sarah Pearson-Baird in Dubai – secured a judgment from the High Civil Court (Seventh Chamber for Corporate Reorganization and Bankruptcy) that ranks among the first and most significant judicial applications of the cross-border insolvency provisions in the Kingdom of Bahrain.

Pursuant to Article (172) of the Reorganization and Bankruptcy Law issued by Decree-Law No. (22) of 2018, the Court recognised the compulsory liquidation proceedings of AmazingTech Pte Ltd – operator of the Tokenize Xchange digital asset trading platform – issued by the High Court of the Republic of Singapore as a foreign main proceeding under Chapter Five of the Law. This milestone underscores the maturity and sophistication of Bahrain’s legislative and judicial framework.

This judgment represents a practical and advanced application of the cross-border insolvency provisions, one of the most developed branches of international commercial law, as it aims to foster cooperation between national and foreign courts, ensure the unified administration of the debtor’s assets, and prevent conflicting judicial proceedings across different jurisdictions. The Kingdom of Bahrain is among the leading jurisdictions in the Arabian Gulf to have adopted harmonised international insolvency standards through its incorporation of the UNCITRAL Model Law within the Reorganization and Bankruptcy Law. Working alongside DLA Piper, Al Doseri Law demonstrated the ability to translate this advanced legislative framework into practice before the Bahraini judiciary, providing essential legal guidance on the Bahraini reorganisation and bankruptcy regime and its alignment with the UNCITRAL Model Law.

After an extensive review of the documents and foreign judgments submitted, the Court concluded that all legal conditions for recognising the liquidation proceedings issued by the High Court of Singapore had been met, given that the company’s center of main interests is located in that country, that the liquidation proceedings were issued by a competent judicial authority, and that the requirements stipulated in the Bahraini Reorganization and Bankruptcy Law had been satisfied. By way of background, AmazingTech was incorporated in 2016 and operated a digital asset exchange platform allowing customers to buy, sell and hold over 130 types of digital assets. In August 2025, the Monetary Authority of Singapore (MAS) rejected AmazingTech’s licence application to provide digital payment token services – the company having previously operated under a temporary exemption during Singapore’s transition to the 2019 Payment Services Act – finding indications that the company did not have sufficient assets to meet its customers’ claims and may not have properly segregated customer assets. MAS had launched its investigation following customer complaints over delays in processing withdrawals of monies and digital payment tokens. AmazingTech director Hong Qi Yu was also charged in court for fraudulent trading, with the company and its related entities under investigation by Singapore’s Commercial Affairs Department. Following the MAS announcement, creditors applied to place the company into interim judicial management, and Cameron Duncan, David Kim and Joshua Jeyaraj of KordaMentha were appointed as interim judicial managers (IJMs) on 15 August. Tasked with assessing whether AmazingTech could be rehabilitated, the IJMs concluded in September that the company was insolvent and had ceased operations, and applied to place it into liquidation. Justice Philip Jeyaretnam of the Singapore High Court wound up AmazingTech and appointed Duncan, Kim and Jeyaraj as joint liquidators on 30 September. The liquidators applied for recognition in Bahrain on 23 April, after discovering that the company held a bank account with Bank of Singapore Gulf in the Kingdom of Bahrain containing deposits of approximately S$129,500 (US$100,300), which the bank declined to release absent recognition by a Bahraini court. Al Doseri Law — in its capacity as local legal counsel — in coordination with the international firm DLA Piper, succeeded in formulating a cross-border legal strategy that led to the issuance of this judgment.

The judgment was not limited to merely recognising the foreign proceeding, but extended to recognising the liquidators appointed in Singapore — namely Cameron Lindsay Duncan, Joshua Jeyaraj, and David Dong-Won Kim, of KordaMentha (Singapore) — as the foreign representatives of the company. It also arranged all of its legal effects within the Kingdom of Bahrain, staying lawsuits and enforcement proceedings relating to the company’s assets within the Kingdom, and appointing a trustee to administer and liquidate the assets located in Bahrain, granting the trustee authority to cooperate directly with the foreign court and the foreign representative, under the supervision of the Bahraini court, so as to ensure the unity of the liquidation proceedings and protect the rights of creditors.

Trust and Standing: Bahrain as a Trusted Regional Financial and Legal Hub

The significance of this judgment is that it embodies the confidence the Bahraini judiciary places in foreign judgments and judicial proceedings once they satisfy the legal requirements of Chapter Five of the Reorganization and Bankruptcy Law. At the same time, it affirms the Kingdom of Bahrain’s commitment to modern international standards in addressing cross-border insolvency and bankruptcy cases, reinforcing its standing as a regional financial and legal hub that offers a judicial environment characterized by efficiency and legal certainty. Commenting on this achievement, lawyer and arbitrator Saad Al Doseri, founder of Al Doseri Law, stated: “This decision represents a pivotal moment in the field of cross-border insolvency in the Gulf region. It confirms that the Kingdom of Bahrain’s adoption of the UNCITRAL Model Law on Cross-Border Insolvency is not merely theoretical legislation, but a robust and effective legal framework capable of delivering tangible results for international creditors and insolvency practitioners. We are proud of our fruitful coordination with the international law firm DLA Piper – led by partner Jared Green and his team – in achieving this landmark recognition, which cements Bahrain’s position as a trusted and forward-looking jurisdiction in the field of international judicial cooperation in insolvency matters.”

The judgment further affirms that recognition of foreign proceedings is not a mere formality, but is subject to rigorous judicial scrutiny. The Court verified the jurisdiction of the foreign court, the debtor’s center of main interests, the standing of the foreign representative, and the fulfilment of all formal and substantive requirements stipulated in the law. Notably, the Court confirmed that no insolvency proceedings had been commenced against AmazingTech in Bahrain, and the liquidators confirmed that the company had no creditors in the Kingdom whose rights might be affected by recognition, before arranging the legal effects within the Kingdom of Bahrain. From a practical standpoint, this judgment sends a clear message to financial institutions, banks, and multinational companies that the Bahraini judiciary possesses an advanced legal framework for dealing with international bankruptcy cases, achieving a balance between respecting foreign judgments and protecting public order and rights within the Kingdom.

The judgment acquires particular importance in light of the growing number of disputes involving cross-border enterprises, digital assets, and international financial institutions. Its relevance is clearly illustrated by the case at hand: AmazingTech Pte Ltd operates the Tokenize Xchange digital asset trading platform and holds assets across multiple jurisdictions — precisely the type of matter requiring specialised cross-border coordination expertise, which Al Doseri Law demonstrated in partnership with DLA Piper. As a benchmark judicial application, this judgment may pave the way for enhanced cooperation between judicial authorities across borders and contribute to more efficient and transparent asset recovery and liquidation administration. It confirms that Bahrain now possesses a legal and judicial system fully capable of keeping pace with global developments in international insolvency, thereby strengthening investor and institutional confidence in the Bahraini legal environment.

From Legislation to Application: The UNCITRAL Model Law Proves Its Effectiveness in Bahrain

The application submitted to the High Court — drafted and presented by Al Doseri Law in its capacity as Bahraini legal counsel in coordination with the international law firm DLA Piper — was based on the provisions of Chapter Five of Decree-Law No. (22) of 2018 on Reorganization and Bankruptcy, entitled “Cross-Border Insolvency.” This is the chapter that the Bahraini legislator drew from the UNCITRAL Model Law on Cross-Border Insolvency issued by the United Nations Commission on International Trade Law (UNCITRAL), reflecting the Kingdom’s orientation toward adopting international best practices in this field. This legislative philosophy is clearly manifested in Article (165) of the Law, which provides that, for the purposes of interpreting the provisions of this chapter, regard shall be had in particular, where appropriate, to what is issued by UNCITRAL regarding the Model Law on Cross-Border Insolvency. This provision confirms that the Bahraini legislator did not merely draw inspiration from the provisions of the Model Law when enacting the legislation, but also mandated reliance on the interpretive guides and commentaries issued by UNCITRAL when applying cross-border insolvency provisions, thereby promoting uniformity of judicial interpretation and achieving consistency with international principles and practices in this field.

About the UNCITRAL Model Law on Cross-Border Insolvency:

The UNCITRAL Model Law on Cross-Border Insolvency is a model legislation issued by the United Nations Commission on International Trade Law (UNCITRAL) in 1997, aimed at assisting states in equipping their legal systems with a modern and effective framework for addressing cross-border insolvency cases — that is, cases in which the insolvent debtor owns assets or has creditors in more than one country. It is not a binding international convention, but rather a “model law” that states use as guidance when enacting their national legislation, with the freedom to modify it to suit their domestic legal system — which is precisely what the Kingdom of Bahrain did when it adopted it within the Reorganization and Bankruptcy Law (Decree-Law No. 22 of 2018).

This judgment holds special standing as one of the first Bahraini judicial applications to bring this legislative vision to life. Beyond recognising the foreign liquidation proceedings, it entrenched the core principles of the UNCITRAL Model Law, international judicial cooperation, mutual recognition of insolvency proceedings, preservation of the debtor’s assets, unified insolvency administration, and maximisation of creditor protection. The judgment is therefore not merely an application of domestic legal provisions, but a testament to the Bahraini judiciary’s alignment with the highest international standards in cross-border insolvency, cementing the Kingdom’s position as a financial and judicial hub with an advanced, globally harmonised legal system. Building on this achievement, Al Doseri Law, under the leadership of lawyer and arbitrator Saad Al Doseri, reaffirms its commitment to continuing its leadership in cross-border insolvency and international commercial disputes, and to strengthening its strategic partnerships with leading international law firms, in service of its clients and investors and to enhance confidence in the Kingdom of Bahrain’s legal environment.

This article was published in Gulf Daily News, 29 July 2026, here.

Key participants in this matter:

AmazingTech joint liquidators – KordaMentha partners Cameron Duncan, David Kim and Joshua Jeyaraj in Singapore.

Counsel to the liquidators – DLA Piper:

Partner Jared Green and associate Daniel Huang in Singapore, partner Peter Somekh and legal director Sarah Pearson-Baird in Dubai.

Local counsel – Al Doseri Law: founding partner Saad Al Doseri in Bahrain.