How Does the Enforceability of Netting Vary across International Jurisdictions?

The enforceability of netting, particularly close-out netting, varies significantly because it depends on the insolvency and bankruptcy laws of each jurisdiction. While major financial centers generally uphold netting agreements, some countries may have laws that allow a bankrupt entity's administrator to "cherry-pick" favorable contracts, undermining the core principle of netting.

This necessitates legal opinions on enforceability.