Written by: Dr Victor Meijers, lecturer at Leiden University and Civil-Law Notary in The Hague, and Jinghan Cheng, Chinese Lawyer in The Hague.
With increasing financial sanctions imposed on Chinese companies by the US government in recent years, the practice of long-arm justice is ever more relevant for international business. In this article, we will discuss long-arm justice in the US once we have looked at a brief introduction to similar practices historically in China and international institutions like the UN.
(1) History of extraterritoriality in China
The term “long-arm justice” is a comparatively recent concept that is more publicly known as a US practice. However, jurisdiction models with “long-arm” characteristics, i.e., a certain country’s far-reaching power of authority, can be traced back much further in different regions of the world for various historical and practical reasons. Among different models, there is one example in Chinese history that draws our attention, which is called extraterritoriality.
Extraterritoriality is commonly defined as the right of foreign citizens to be tried by the laws of the country they are from, not the laws of the country where they live. The creation of extraterritoriality for treaty nations in 19th Century was not totally new to China since there used to be differential treatment of subjects who were Han or Manchu , the latter of which possessed legal privileges that sometimes placed them outside the jurisdiction of local ethnically Chinese administrators.
The above-mentioned historical practice had already familiarised China with extraterritoriality at the time of the Qing empire. At the negotiations of the Treaty of Nanjing, Qing negotiators readily extended a grant of extraterritoriality to the British because sovereignty was held by peoples rather than imposed on lands at that time.
A more formal declaration of extraterritoriality in the Qing Dynasty was concluded in the 1843 Supplementary Treaty of the Bogue, which established that “Britons were to be punished according to English Law and Chinese were to be ‘tried and punished by their own laws'”.
Against this background, such privileged treatment was extended to further western countries that also wanted reassurances and guarantees from the Qing government. Therefore, foreign governments could enjoy extraterritoriality privileges that protected their citizens or traders under full protection of the Chinese law. Such legal treatment was later granted to all interested western powers due to the “most-favoured-nation” clause, which meant that all privileges the Qing empire granted to one power would be automatically granted to others. Subsequently, the territorial rights of the Qing Empire were greatly harmed, which is a manifest of foreign countries’ historical “long-arm” judicial practices during the Qing Dynasty. This long-arm policy meant that foreign countries were able to reach out to their own citizens in China and provide legal protection at that time when legal conflicts occurred easily, without interference of the country where their citizens resided, i.e., China.
Under the influence of the extraterritoriality policy, Shanghai became one of the most typical of the treaty ports established after the Opium Wars, where extraterritoriality provisions were implemented in the most sophisticated manner. Examples of extraterritoriality in China and more specifically in Shanghai were two main courts judging extraterritorial cases, which were the Shanghai Mixed Court and the British Supreme Court for China. Similar courts were established for other treaty countries, e.g., the United States Court for China. These courts had jurisdiction over the concession areas, which formally remained under Qing sovereignty. What is interesting is that the principle of extraterritoriality was not reciprocal: Chinese citizens in California at that time were not protected by Qing legislation. This long-term extraterritoriality policy existed for many years until it finally ended at various times in the 20th century, after the collapse of the Chinese government in 1911 and the effects of World War II which led to the abolition of extraterritoriality in nearly all areas of China in 1943. Examples like the Sino-American Treaty for the Relinquishment of Extraterritorial Rights in China and the Sino-British Treaty for the Relinquishment of Extra-Territorial Rights in China are representative of the end of this policy of extraterritoriality.
Extraterritoriality has in a way made a deep impact and has caused mainland China’s and Chinese policymakers’ sensitivity towards international law, international organisations, and more recently, human rights issues. With part of its legitimacy resting on claims of strengthening national sovereignty and territorial integrity, the Constitution of the People’s Republic of China explicitly states that foreigners must abide by PRC law. Additionally, the Chinese government claims the right to prosecute Chinese citizens for crimes against the criminal code which were committed abroad, even if these citizens have already been punished for the crime by the relevant country.
So, we see that these historical consequences have led to significant focus on the importance of national sovereignty in mainland China. Partly due to this reaction to China’s sovereignty being affected by extraterritoriality policies in the past, few other nations currently emphasise the importance of their sovereignty more than China does today.
Having considered extraterritoriality policy in the history of China, it will be interesting to take a look at a more recent case which is representative of China’s application of long-arm justice in crypto-currency.
The case concerns the so-called PlusToken scam, which led to the arrest of 109 individuals in China and reportedly resulted in a titanic seizure of crypto assets by Chinese authorities worth an estimated US$4.2 billion. Before diving into how long-arm justice was applied in this case, we will briefly introduce the PlusToken case.
PlusToken was a crypto-currency Ponzi scheme that operated in China and Korea. The scam lured unsuspecting investors by offering massive returns on their investments. For instance, for every investment made, it offered 9% to 18% monthly returns. Hence, an enormous investment would lead to higher returns. However, all returns for early investors were generated by later investors. Notably, the classic scam mainly depended on conferences to promote the dubious scheme. Reports also noted that the PlusToken mobile application allowed people to easily convert KRW or RMB into a myriad of digital assets. Eventually, investors lost nearly 40 billion Chinese Yuan, approximately US$5.7 billion.
On 26 November 2020, the Intermediate People’s Court of Yancheng City, Jiangsu Province, issued a second-instance criminal ruling on the above case, deciding to uphold the original verdict, including prison sentences and penalties. Before the scheme’s ringleaders were arrested, to avoid legal action, they had moved the customer services team and coin-dealing team outside of China to Sihanoukville, Cambodia. They continued to hide abroad in order to avoid Chinese jurisdiction after their crimes had come under investigation of Chinese judicial authorities. The Chinese government’s determination to track down crypto-currency scammers and hold them to account, and its application of extraterritorial jurisdiction based on criminals’ nationality have led to a result of arrests, prosecution, and convictions. This legal approach with regard to criminals residing outside of China resembles the characteristics of “long-arm justice”, however it is not entirely the same. Nevertheless, it wins China and the Chinese justice department control over its own judicial power: the successful prosecution of criminals who commit such cross-border scams has shown the judicial sovereignty of China abroad and its proactive application of “long-arm” judicial power overseas.
In an increasingly global society, criminality has also gained global characteristics. Therefore, law enforcement is following international criminals across the globe. Under the rule of law, in an ideal world, such international activities will be founded in international treaties that clearly define “international jurisdiction”, also to avoid conflicts between nation states in defining what is “criminal”. In other words: there should also be an international “rule of law”.
(2) The power of the United Nations and its universal jurisdiction
Having looked at extraterritoriality policy in the history of China, we will continue to analyse another similar yet different legal concept which still exists in international society at present: universal jurisdiction. The two concepts partly overlap, but each also has distinct characteristics. Whereas extraterritoriality tends to result in debate over its application, because exercising extraterritorial jurisdiction is not necessarily welcomed by nation states and can be seen as an infringement on their territorial integrity, universal jurisdiction, which arises from the idea that some crimes are so repugnant to all humankind that any nation may try the perpetrators, has won general recognition in international society. It has made important headway in the case against extraterritoriality. Among international players who promote universal jurisdiction, the United Nations is actively involved and representative of how “long-arm” policy is practiced in international society from a positive perspective.
The United Nations (the UN) is an international organisation, founded as a result of WWII in 1945, that is currently made up of 193 Member States. The mission and work of the United Nations are guided by the purposes and principles contained in its founding Charter. The UN Charter, in its Preamble, sets the objective: “to establish conditions under which justice and respect for the obligations arising from treaties and other sources of international law can be maintained”. Due to the powers vested in its Charter and its unique international character, the UN can take action on issues confronting humanity in general, such as peace and security, climate change, human rights, disarmament, terrorism, humanitarian and health emergencies, gender equality, food production, and so on.
The work of promoting international law and justice is carried out in many ways which align with positive goals of reaching international peace. This work is carried out by courts, tribunals, multilateral treaties and by the Security Council, which can approve peacekeeping missions, impose sanctions, or authorise the use of force in case of a threat to international peace and security, if it deems this necessary. These powers are granted by the UN Charter, which is considered an international treaty. As such, it is an instrument of international law, and UN Member States are bound by it. The UN Charter codifies the major principles of international relations, from sovereign equality of Member States to the prohibition of the use of force in international relations, which also grants the UN rights of exercising jurisdiction in different countries in specific scenarios. In today’s world, the “long-arm” characteristics are interpreted in a positive way to promote equal justice in international conflicts between nation states, rather than being abused as a way to intrude on the sovereignty of less developed countries by more economically and politically dominant nations.
The principal judicial organ of the United Nations is the International Court of Justice (ICJ). This main body of the UN settles legal disputes submitted to it by Member States in accordance with international law. It also gives advisory opinions on legal questions referred to it by authorised UN organs and specialised agencies. In addition to the International Court of Justice, a wide variety of international courts, international tribunals, ad hoc tribunals and UN-assisted tribunals have varying degrees of relations to the United Nations. The International Criminal Court (ICC) and International Tribunal for the Law of the Sea (ITLOS) were originally established by conventions drafted within the UN, but are now independent entities with special cooperation agreements, so not all UN members submit to the jurisdiction of such courts and tribunals.
The most dominant principle of jurisdiction exercised by the UN is universal jurisdiction, which allows states or international organisations to claim criminal jurisdiction over an accused person regardless of where the alleged crime was committed, and regardless of the accused’s nationality, country of residence, or any other relation with the prosecuting entity. Crimes prosecuted under universal jurisdiction are considered crimes against all, crimes which are considered too serious to tolerate jurisdictional arbitrage.
The concept of universal jurisdiction is closely linked to the idea that some international norms are shared by the entire world community, as well as to the concept of jus cogens which means that certain international law obligations are binding to all states. Therefore, it is permissible for the UN to intervene with the prosecution of certain criminals regardless of their nationality or place of residence.
The United Nations Security Council Resolution 1674 “Reaffirm[ed] the 2005 World Summit Outcome Document regarding the responsibility to protect populations from genocide, war crimes, ethnic cleansing and crimes against humanity” and commits the Security Council to action to protect civilians in armed conflict. Examples of universal application are the set-up of some international tribunals, e.g., the International Criminal Court (ICC) is an international tribunal of general jurisdiction to prosecute Member States’ citizens for genocide, crimes against humanity, war crimes, and the crime of aggression, as specified by several international agreements. So far, there have been only two specific situations where the United Nations Security Council have referred to the ICC. One is the International Criminal Court investigation in Darfur with ICC indictment of five people for genocide, crimes against humanity and war crimes. The other the investigation into alleged crimes against humanity and war crimes committed in the context of the volatile situation in Libya since 15 February 2011.
In addition, the UN has also set up other geographically specific courts to investigate and prosecute crimes against humanity under the theory of universal jurisdiction, e.g., the International Criminal Tribunal for Rwanda (1994), and the International Criminal Tribunal for the Former Yugoslavia (1993).
All the above-mentioned jurisdiction rights exercised by the UN are representative of how “long-arm” policies are demonstrated in international society based on a positive purpose of promoting joint peace and justice. Abuse of extraterritoriality policy in history, as a negative example of exercising legal jurisdiction outside a nation’s territory, is no longer appreciated. However, it is quite promising to see the rise of universal jurisdiction in the UN and how “long-arm” justice can be utilised in a positive way in international society. A logical next step could be that universal jurisdiction will become truly global, which could also limit the practice of individual countries interfering in other nation states’ internal affairs.
(3) Long-arm justice in the US
Having analysed universal jurisdiction as regards the UN, we should also take a look at specific examples of legal conflicts being settled outside this UN judicial framework between individual countries which also have “long-arm” characteristics based on the background of a worldwide flow of capital and persons.
Long-arm justice is the ability of local courts to exercise jurisdiction over foreign defendants, whether on a statutory basis or through a court’s. This jurisdiction permits a court to hear a case and enter a binding judgment against a defendant residing outside the jurisdiction concerned. Long-arm justice is also defined as the ability of one country to enforce its laws and rules over entities from another country through its own courts.
In the US, such jurisdiction over non-US companies can be exerted through means such as national security reviews of foreign investments, anti-money-laundering and anti-corruption laws, and securities regulations. Different states possess their own respective “long-arm” statutes, whether on specific types of cases or to grant jurisdiction more generally.
The “long-arm” statute in the US is a statute that allows for a court to obtain personal jurisdiction over an out-of-state defendant on the basis of certain acts committed by this out-of-state defendant, provided that the defendant has a sufficient connection with the state. When a court has jurisdiction due to a “long-arm” statute, the court is said to have “long-arm” jurisdiction.
To begin with, we must know that long-arm justice in the US did not appear out of nowhere.
Section 317 of the Patriot Act, enacted under the influence of the aftermath of the 9/11 attacks, established a global financial counter-terrorism and anti-money-laundering regulatory framework, which as a result, established the rule of long-arm justice over foreign money-launderers. This bill leaves other countries incapacitated in the face of the rule of long-arm justice because many international business banks are inseparable from the US dollar and they heavily rely on US financial institutions with the responsibility of US dollars clearing. Failing to cooperate with the implementation of the US counter-terrorism and anti-money-laundering measures would result in the risk of being cut off by the US financial department, which would be a disaster for many international banks and financial institutions because this may put their international business into stagnation and cause them loss of customers. Although the Patriot Act is now being considered and debated more critically, its influence on how the US investigates foreign companies cannot be denied.
With the US still centrally implicated in worldwide financial business as well as financial crises, the wave of finance and commerce-related litigation in cases arising outside the United States has trapped many institutions and individuals that are based in the US or simply have ties to the US: they find themselves to be plaintiffs, defendants, investigatory targets or third-party witnesses in a variety of foreign proceedings without notification beforehand. The US exerts its global financial and economic influence not only through the success of the US dollar and Wall Street, but also through legal strategies like long-arm justice which has been applied in some important cases so far.
The establishment and application of long-arm justice in the US is based on the fulfilment of some basic requirements. Typically, a “long-arm” statute will grant a court jurisdiction over a non-resident if this resident has minimum contact within the court’s jurisdiction.
The minimum requirements for US long-arm justice were established following the conclusion of some cases. In International Shoe Co. v. Washington, 326 US 310 (1945), the Supreme Court held that for a defendant to have minimum contact, the defendant needs some combination of the following two factors:
(1) systematic and continuous activity within the forum jurisdiction;
(2) a cause of action arising from that activity.
In Asahi Metal Industry Co. v. Superior Court, 480 US 102 (1987), the Supreme Court clarified that even if the defendant has (had) minimum contact, a court’s asserting jurisdiction over the defendant may still be improper as it could be unfair to the defendant.
The Asahi court held that even in case “minimum contact” applies, the court still needs to consider certain consequences of asserting personal jurisdiction. These consequences include the burden on the defendant, the interests of the forum state in the action, the plaintiff’s interest in having the forum state exercise jurisdiction, and overall efficiencies of having the forum state exercise jurisdiction. Although it seems that the application of long-arm justice is based on certain standards, financial and political conflicts between countries make long-arm justice more complicated in reality. Nowadays, companies that think they and their employees are beyond the reach of US authorities may have to reflect on their position again because there are more cases showing that some foreign companies find themselves subject to US jurisdiction unknowingly. In the application of long-arm justice, US enforcement authorities are aggressively interpreting and applying US criminal laws to companies and individuals outside the United States even when their conduct has little nexus with the US.
For example, US regulatory and enforcement officials hold that the mere transit of emails through the US is enough to reach investigation requirements under US criminal law, even when these emails are sent from one person outside the United States to another person also outside the United States. The issue of the physical location of servers facilitating email traffic and storage therefore leads to practical consequences. Similarly, US authorities may assert that transit of money through the United States on its way from one non-US location to another non-US location is enough to subject the targeted companies to US criminal jurisdiction. The privileged role of the US in the world economy sometimes leads the US to take it upon itself to become the world’s policeman, judge and jury, without the possibility to appeal.
There are some noteworthy cases that demonstrate long-arm justice in the US.
a. Huawei case:
As a large corporation with global reach, Huawei has come under fire recently due to some countries’ suspicions of its potential security threats. There are concerns that with the expansion of Huawei’s infrastructure and the proliferation of Huawei’s products all around the world, this hardware can be tapped into for surveillance and espionage. Responding to these suspicions and accusations, Huawei has released their annual reports audited by KPMG to show that Huawei is a private company, wholly-owned by its employees. Huawei makes the point that the Chinese government does not hold a single share in the company. Furthermore, Huawei states that any government subsidies, bank loans and tax incentives it may receive are no different to those received by its major competitors. Despite these statements expressed by Huawei, an escalation still occurred under the influence of long-arm justice applied by the US government.
On 1st December 2018, Ms Meng Wanzhou, CFO of the Huawei corporation, was arrested in Canada at the request of a New York court, and is currently facing charges related to Huawei’s purported violations of US sanctions on Iran. The defendant has presented evidence to show that Meng Wanzhou did not conceal facts from HSBC, which is a lender involved in Huawei’s dealing with Iran. Meng’s lawyer claimed that Meng had provided HSBC executives with all relevant facts concerning Huawei’s business in Iran. Meng’s lawyer also stressed the fact that Meng had informed HSBC of the necessity of assessing its risk of doing business with Huawei. Meng claimed that she was the victim of a “fraud”, in which HSBC was accused of lying about Huawei and its being aware of Huawei’s activities in Iran during an investigation by the US department of justice. The accusation was even implied by People’s Daily in China although it was later explained by HSBC in its clarification statement. The final investigation into the facts behind those accusations and explanations is yet to be concluded. What has become clear is that HSBC didn’t suffer from financial losses because the United States did not punish HSBC – instead, the US opted to bypass HSBC and prosecute Huawei and Meng Wanzhou, despite her having no apparent direct relations with the United States.
This was enabled by way of US long-arm justice, which allows the enforcement of US laws on foreign nationals. Meng’s arrest via the use of said long-arm justice has sparked widespread controversy and ties in with further contentious questions of geopolitics with a particular focus on China’s rise, national security, and the rule of law.
In addition to the Huawei case, there have been other cases where the US government has tried to apply long-arm justice but failed, which show that long-arm justice does not always turn out entirely favourably in all cases from the perspective of the US
b. Morrison v. National Australia Bank Ltd.
The case concerned is the 1998 purchase by the National Australia Bank (NAB) of a mortgage servicing company, HomeSide Lending, headquartered in Florida.
In July 2001, NAB announced a US$450 million write-down in assets due to losses associated with HomeSide Lending, followed by a further US$1.75 billion write-down in September of that year. The plaintiffs claimed that this was part of an intentional scheme to defraud, committed by HomeSide Lending’s management.
Before the case reached the US Supreme Court, only Australian investors appeared as plaintiffs, although a US investor had participated in earlier proceedings. The plaintiffs argued that the fact the alleged fraud occurred in Florida meant that it should be subject to US securities laws. The defendants argued that, since the alleged fraud related to trading in Australian securities, US securities laws did not apply.
In the end, the judgement was unanimous in favour of the defendants. The opinion held that since the plain language of section 10(b) only applies to US securities, it should not be read to apply to non-US securities, even though there were other long-standing precedents, originating in the 2nd Circuit, that 10(b) also applies to non-US securities.
From the above two cases we can see that, in spite of long-arm justice being an indispensable part of US jurisdiction, there are some restrictions to its application.
However, as an effective tool used by US authorities to control or supervise some transactions and technology-based business among cross-border companies and international financial institutions, long-arm justice needs to be analysed by multinationals’ professional teams so they can take effective measures to avoid being scrutinised unknowingly by US authorities. It is still questionable what effects long-arm justice will bring to the US and countries considered as potential competitors to the US as the world economy is becoming increasingly more interrelated.
c. CSE Global Limited Case
Between August 25, 2010 and November 5, 2011, TransTel entered into contracts with, and received purchase orders from, multiple Iranian companies to deliver and install telecommunications equipment for several energy projects in Iran and/or Iranian territorial waters. CSE TransTel hired and engaged several different third-party vendors, some of which were Iranian companies, to provide goods and services on its behalf in the above-referenced contracts and purchase orders. Neither CSE Global nor CSE TransTel are registered or based in the US The only connection between the CSE TransTel and the US is its dominant use of US dollars in its agreement with Iranian distributors, the latter of which is the important factor that drew the US’s attention and led to the US authorities putting the agreement under stricter scrutiny.
As a result, The Office of Foreign Assets Control (OFAC) determined that TransTel had not voluntarily self-disclosed the apparent violations, and these apparent violations resulted in a fine of over US$12 million on CSE TransTel.
Long-arm justice here is based on a breach of the Iran-sanction rules imposed by US authorities. Although CSE TransTel apparently did their business with due procedure and followed legal requirements of providing certain documents, their failure to voluntarily disclose their connection with Iranian companies during a US$-dominant business transaction, a failure caused by their negligence with respect to long-arm justice applied by the US authorities, made them fall within the jurisdiction of the US authorities. It is worth noting that companies may still face charges even though they act in good faith and believe they have followed the rules. Any company that conducts US$-dominant transactions with nation states that are deemed threats to US national security interests should be exceedingly cautious with their business dealings.
Through this case, we can see that US authorities can exercise extended jurisdiction involving sanctioned countries and parties like Iran in all forms of property. Most US$-dominant transactions can fall within the jurisdiction of US authorities. The broad reach of the US’s jurisdiction is not merely limited to the use of US dollars in business with companies in sanctioned countries; it can reach to all kinds of money transaction processes related to US dollars. Many US laws, like the Foreign Corrupt Practices Act (FCPA) and various anti-fraud statutes, may establish jurisdiction over a crime which involves the use of any “means or instrumentality of interstate or foreign commerce.” The reach of US jurisdiction over money transactions or the use of US dollars can cover any communication or movement that internally crosses state or externally crosses international borders, including wire transfers, emails, phone calls, mail and travel.
Given the broad reach of US commerce, from free email servers to correspondent banks that clear US dollars for non-US-based banks, such a broad definition of long-arm justice and its application can significantly increase the reach of US laws.
d. NHK Spring Co. Ltd case
NHK Spring Co. Ltd. (NHK Spring) is a Japanese manufacturer of suspension assemblies used in hard disk drives. According to a charge filed in the US District Court, NHK Spring had reached agreements with co-conspirators to refrain from price competition and allocate their respective market shares.
Pursuant to their agreements not to compete, NHK Spring and its co-conspirators allegedly exchanged pricing information including anticipated pricing quotes, which they used to inform their negotiations with US and other foreign customers purchasing suspension assemblies and producing hard disk drives for sale in, or delivery to, the US and elsewhere. Subject to court approval, the company has agreed to plead guilty, to pay a US$28.5 million criminal fine, and to cooperate in the ongoing investigation.
The United States department of Justice in the US (DOJ) and Federal Trade Commission (FTC) also make the most of long-arm justice and occasionally bring anti-trust charges against non-US companies or individuals. In addition to the indictment against NHK Spring, the DOJ also indicted individuals in the case for conspiracy in their individual capacities as a result of the same conduct.
e. Meta Ullings Case
After taking above international companies as examples, it is also interesting to take a look at a case relating to a Dutch national, which again is an anti-trust case. Long-arm justice in the US is more widely and easily applicable in large company cases in an anti-trust related field, especially when such companies fail to comply with stricter anti-trust rules.
Maria Christina “Meta” Ullings is the former Senior Vice President of Cargo Sales and Marketing for Dutch company Martinair Holland N.V. (Martinair Cargo with registered address Schiphol Airport, the Netherlands) who pleaded guilty to engaging in a long-running air-cargo price-fixing conspiracy charged by the US authorities. An assistant attorney in the Department of Justice’s Anti-trust Division commented that the Anti-trust Division is determined and committed to combating anti-trust crimes no matter where the companies involved in such crimes are located or registered. Such a determination shows the US authorities’ confidence in their application of “long-arm” jurisdiction. Including Martinair and Ms Ullings, a total of 22 airlines and 21 executives have been charged in the Justice Department’s investigation into price-fixing in the air-transport industry. So far, there have been more than US$1.8 billion worth of criminal fines imposed by the US authorities and eight executives have been sentenced to serve prison time.
In this case and other air-transportation cases investigated as part of long-arm justice in the US, many departments have become involved, including the Anti-trust Division, the FBI, The Department of Transportation’s Office of the Inspector General and the US Postal Service’s Office of the Inspector General, which also emphasises the importance of long-arm justice to the US. The determination of US authorities to deliver justice reaches all aspects of international business.
It is undeniable that long-arm justice is exploited in all aspects in the US. More recent cases as indicated above represent the current unilateral interpretation of long-arm justice and its prevalence. The jurisdiction principle underscores the US government’s ability to control and regulate foreign commercial and business practices without possibilities to appeal. From an academic perspective, it is remarkable that a nation state can give itself such authority without the counterbalance of international accountability. The necessity of long-arm justice in a more globalised society is evident, but the “rule-of-law” framework is not yet in place. From a practical perspective a caveat is in order. Foreign companies doing international business that potentially get scrutinised by US inspection must carefully take mandatory requirements under US law into consideration.
Dr. Victor Meijers
Dr. Meijers’ main interests are corporate law and non-governmental organizations (NGOs), incorporated partnerships, and the trade register of the Chambers of Commerce. Victor Meijers was appointed by the Crown as civil-law notary by Royal decree on July 4th, 2005.
Dr. Meijers set up Civil Code on May 20th, 2005 as a Dutch public limited liability company (N.V.). DeHeng Civil Code is a dedicated Dutch law firm with Chinese roots that specializes in Dutch corporate law. DeHeng Civil Code can assist clients from all over the world in M&A work and corporate work governed by Dutch law or with Dutch law implications.
