Anahata Solutions

How to recover debt from a holding group dispersed across jurisdictions.

This case illustrates a situation where the debt formally arises within one company, while the actual financial capacity to repay it is distributed among several others operating in different countries.

On paper, the situation looks simple: there’s a contract, a debtor, and a confirmed amount owed. But behind the legal entity stands a complex international structure, where each business unit plays a distinct, legally separated role.

When a dispute arises, this structure acts as a shield: liability becomes blurred, access to assets is obstructed, and time and resources are consumed fighting against “shells.”

Our task wasn’t to break through these barriers head-on, but to find precise and systemic points to bypass them.

Context: the debt is here, the money is next door

A Chinese manufacturer faced unpaid debt from a large holding composed of several business entities across multiple countries. The contract had been signed with a Russian subsidiary — the one least able to pay due to sanctions, currency restrictions, and enforcement difficulties.

The client posed the key question: Can the debt be recovered not through the named debtor, but through other group companies — where the assets and actual solvency lie?

The challenge: legal boundaries as shields of liability

The holding employed a classic model of corporate isolation: each company operated formally on its own, with obligations confined to the “local level.”

This presented three core barriers:

— How to establish a link between the Russian “subsidiary” and the group’s parent company?

— How to take enforcement beyond Russia if the contract was signed within its jurisdiction?

— How to avoid wasting years and budgets in jurisdictions that won’t deliver a result?

Strategy: don’t go through the debt — go through the structure

We started with the most important step: understanding how the holding truly functions beyond the formal chart.

Our research revealed critical links:

— Who holds management and operational control;

— How funds circulate between entities;

— What resources (IP, personnel, infrastructure) are shared;

— Where ownership, signatories, and financial authorizations intersect.

Based on this, we developed a legal argument showing that — despite the contract being with a Russian entity — the real economic benefits and managerial decisions originated from international business units. That’s why they could bear partial responsibility under applicable laws.

Where to find assets and how to apply pressure

Simultaneously, we identified where the group had economic presence outside Russia — and what could be targeted effectively. We located bank accounts in jurisdictions that recognize international arbitration and allow asset freezing on creditor request. We also found stock reserves in transit hubs and with logistics providers — assets with real value and business sensitivity. Key contracts with third parties were also analyzed for terms that could be leveraged in negotiations or litigation. This insight enabled us not only to identify where the money was, but also to determine where pressure could be applied — legal, commercial, or operational.

Execution beyond Russia: shifting the pressure point

Based on the analytics, we selected a jurisdiction meeting three criteria:

— Presence of group assets;

— Recognition of affiliate liability;

— Practical effectiveness in seizing and enforcing assets.

This avoided engaging with the limited effectiveness of Russian procedures and shifted the enforcement focus to a jurisdiction the debtor had not anticipated — where they had no prepared defensive position.

The client reduced legal costs and gained a real leverage tool that accelerated debt recovery.