Sue in the wrong one and you win a judgment you cannot enforce.
The debtor is incorporated in the Netherlands. The warehouse is in Poland. The bank account — the one that actually has money in it — is in Germany. You obtained a judgment in the Dutch court. The judgment is valid. The debtor has no assets in the Netherlands.
You are holding a piece of paper from the right court in the wrong country. This is the most expensive mistake in international debt collection, and it happens because creditors choose the jurisdiction based on where the debtor is registered rather than where the money is.
Where to file is not where the debtor lives
The purpose of a court judgment is not to be right. It is to be paid. A judgment is only as useful as the assets it can reach. Filing in the debtor's country of incorporation is the default choice but not always the correct one.
Within the EU, Brussels I Recast (Regulation 1215/2012) allows you to enforce a judgment obtained in one member state across all others — but enforcement still requires a separate procedure in the country where the assets are located. A Dutch judgment enforced against a German bank account requires a German enforcement officer (Gerichtsvollzieher), a German court order, and German procedural compliance. The judgment crosses borders. The enforcement is local.
Outside the EU, mutual enforcement depends on bilateral treaties or conventions. A judgment from an English court after Brexit is no longer automatically enforceable in the EU — it must be recognised by the local court under national rules, which vary from smooth (Germany) to slow (Italy) to uncertain (newer EU members).
The asset investigation comes first
Before filing anything, you need to know where the assets are. A debtor with a €2 million claim against them and a registered office in a brass-plate jurisdiction with no assets is not a debtor worth suing in that jurisdiction.
An asset investigation traces bank accounts, real property, equipment, intellectual property, inventory, and receivables owed to the debtor by third parties. This investigation is conducted in each jurisdiction where the debtor operates — not where it is registered, but where it does business. The results determine the filing strategy.
This is why the assessment phase matters more than the filing phase. A professional collection agency with local counsel in multiple jurisdictions runs this investigation before recommending where to file. The cost of investigation is trivial compared to the cost of litigating in a jurisdiction where no assets exist.
The coordination problem
When assets are spread across three countries, you may need enforcement actions in all three — simultaneously, or in sequence, depending on the strategy. The debtor who learns you have filed in Germany may move the Polish warehouse inventory before you file in Poland. The debtor who receives the Dutch judgment may empty the German bank account before you apply for enforcement.
This is why multi-jurisdiction collection is a coordination exercise, not a legal exercise. The legal procedures are standard. The coordination — filing in the right order, at the right time, with local counsel who communicate with each other — is what produces recovery.
A single-jurisdiction law firm cannot do this. They know their own court. They do not know the Polish enforcement timeline or the German bank attachment procedure. You need a network — either a collection agency with local partners in each jurisdiction, or a law firm with genuine (not claimed) cross-border capability.
The practical rule
File where the money is. Not where the debtor is registered. Not where the contract was signed. Not where you are located. Where the money is.
If you do not know where the money is, find out before you file anything. The investigation costs less than the filing. And the filing costs less than the judgment you cannot enforce.
Sofia Lindqvist
Credit Risk Analyst