Sunday, May 31, 2009

Bi-Lingual Credit Agreements

Friday was the first big translation exercise of my summer.  A US corporation is purchasing a German company and we're handling the credit side of things with the foreign bank.  Because the subsidiary, and a bunch of other holding companies are all registered in Germany, German corporate law applies.  But US law also applies to all the contracts.  So the credit agreement and all its parts have to be in step in two jurisdictions at once.

The hard thing about this is that you can't simply translate the documents.  In this case, I was translating from German to English.  The translation had to be effective in the US and also Germany.  So all the key legal concepts had to be recognizable to a German regulator and an American lawyer.

This is a lot easier said than done.  I thought it would take about an hour.  It took four.

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