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Fla. Ruling Opens Door To Foreign Asset Freeze Enforcement

March 2021 Mark J. Forte

Although receiving little fanfare since its issuance, a recent trial court order in Florida state court has sent a warning shot to American defendants embroiled in litigation abroad.

In Gorsoan Ltd. v. Bullock, the Eleventh Judicial Circuit of Florida in Miami-Dade County directly enforced an ex parte, worldwide asset freeze — commonly known as a “Mareva” or “freezing” injunction — originally issued by a Cyprus court.1

U.S. courts have uniformly repudiated the use of the drastic Mareva remedy. Gorsoan, however, represents the clearest affirmation yet that Mareva injunctions will have full force in the U.S. when entered into by foreign jurisdictions.


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Fla. Ruling Opens Door To Foreign Asset Freeze Enforcement


Mark J. Forte
Partner, Head of BVI Litigation & Restructuring and Office

British Virgin Islands   +1 284 852 1113

1Gorsoan Ltd. v. Bullock, 2020-020803-CA-01 (Fla. Cir. Ct. Feb. 17, 2021), Dkt. No. 44.

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