Judgment Enforcement Attorney: When Do You Need Local Counsel to Recover a Foreign Judgment?

You won the case. The court entered judgment in your favour. Months later, no payment has arrived, and the debtor’s most valuable assets appear to be outside the country where the judgment was obtained.

At that point, the nature of the problem has changed. Whether the claim was valid is settled. The questions now are different: Where are the debtor’s assets? Can this judgment be recognised in the jurisdiction where those assets sit? Can the assets be preserved before they disappear? What enforcement remedies are available? And when does the creditor need a judgment enforcement attorney in the asset jurisdiction rather than simply relying on the lawyers who handled the original case?

This article explains what a judgment enforcement attorney actually does, identifies the specific situations where specialist or local counsel becomes necessary, and sets out what an effective enforcement strategy looks like when recovery requires crossing borders.

What Does a Judgment Enforcement Attorney Actually Do?

The role extends considerably beyond sending a demand letter and waiting. In cross-border matters, it involves working through a structured process that begins with the judgment already in hand and ends, ideally, with value actually recovered.

The typical journey looks like this: review the judgment and assess enforceability, identify the debtor and locate recoverable assets, determine which jurisdictions matter, obtain recognition in the enforcement jurisdiction, preserve assets where necessary, deploy enforcement mechanisms, and pursue actual recovery. Each stage involves distinct legal work and, in international matters, may require different counsel in different countries.

Review the Judgment

Before committing to an enforcement strategy, counsel needs to understand what has been obtained. That means verifying that the judgment is final, that no appeal is outstanding or pending, that the monetary amount is definite, that the identity of the judgment debtor is correctly established, and how much time has elapsed since judgment. Limitation periods for enforcement vary between jurisdictions, and a judgment that was recently obtained is in a materially stronger position than one that has been sitting unexecuted for years.

Identify the Debtor and Recoverable Assets

Knowing who the debtor is and knowing where their recoverable assets are located are different exercises. The debtor’s name is on the judgment. Their balance sheet is not. An enforcement lawyer needs to work out what assets exist, where they are held, who legally owns them, and which of them are realistically accessible.

Determine Where Enforcement Should Take Place

If the debtor has assets in multiple jurisdictions, enforcement counsel must evaluate which offers the most commercially rational recovery route. That is a question about the value of the assets, the strength of the evidence connecting them to the debtor, the cost and timeline of enforcement in each jurisdiction, and the risk that the debtor will challenge recognition. Pursuing every jurisdiction simultaneously is rarely the right strategy, and an enforcement lawyer who does not ask the recovery question is not serving the client’s commercial interests.

Coordinate Recognition and Enforcement

A foreign judgment generally needs to be recognised by a local court before local enforcement mechanisms can be used. This may involve registering the judgment under applicable legislation, commencing common-law recognition proceedings, or satisfying local procedural requirements specific to the jurisdiction. Recognition is a prerequisite for enforcement, not a formality that can be skipped.

Pursue Actual Recovery

Recognition gives the creditor access to local enforcement tools. Recovery is using those tools to put value in the creditor’s hands. The two are not the same, and the gap between them is where enforcement strategies either succeed or stall. A judgment enforcement lawyer who understands this distinction manages the full process rather than treating recognition as the finish line.

When Do You Need a Judgment Enforcement Attorney?

1. The Debtor Refuses to Pay the Judgment

Some judgment debtors comply voluntarily. Many do not, particularly where the underlying dispute was contentious and the debtor views the judgment as wrong even if they have exhausted their appeal rights. Where voluntary payment has not followed a reasonable period after judgment and demand, enforcement proceedings become necessary.

The question then is what those proceedings should look like. Enforcement in the jurisdiction where the judgment was obtained is the starting point. But if the debtor has no significant assets there, domestic enforcement mechanisms may produce nothing. That is when the focus shifts to wherever the assets actually are.

2. The Debtor’s Assets Are in Another Country

This is one of the most common scenarios that brings creditors to enforcement counsel. A US business obtains a substantial judgment against a former commercial partner following a contract dispute. The debtor has limited US assets, but owns shares and other interests in The Bahamas, maintains financial accounts in another jurisdiction, and controls an operating business through a company registered abroad.

The US court’s judgment does not automatically extend enforcement authority over those Bahamian assets. The creditor needs Bahamian proceedings to reach them. That requires understanding the applicable recognition route, the available enforcement mechanisms under Bahamian law, and whether any urgent preservation measures are warranted.

ParrisWhittaker’s US judgment enforcement in The Bahamas practice advises US creditors and overseas counsel specifically on this scenario: the recognition route for US judgments, which falls under common-law proceedings rather than the statutory registration framework that applies to certain Commonwealth jurisdictions, and the enforcement mechanisms available once recognition is obtained.

3. The Judgment Needs to Be Recognised in Another Jurisdiction

Recognition and enforcement are distinct steps, and both require careful attention.

Recognition is the process by which a local legal system gives effect to a foreign court’s determination. Enforcement is the use of that locally recognised judgment to pursue available remedies against assets or the debtor directly. In most jurisdictions, recognition must happen before enforcement can proceed.

A judgment enforcement lawyer in the recognition jurisdiction will assess whether the originating court had proper jurisdiction over the defendant, whether the judgment is final and conclusive on the merits, whether there are procedural defences the debtor might raise, what limitation period applies to the recognition application, and which procedure is applicable given the jurisdiction where the original judgment was obtained.

Our guide to enforcing a foreign judgment in The Bahamas explains the Bahamian recognition framework in detail, including the distinction between judgments that can be registered under the Reciprocal Enforcement of Judgments Act 1924 and those that require common-law recognition proceedings. Rather than duplicating that material here, the key point is that every jurisdiction’s recognition requirements are specific, and assuming one country’s rules are the same as another’s is a reliable way to miss a limitation period or concede a procedural defence.

4. You Do Not Know Where the Debtor’s Assets Are

Sometimes the creditor knows a judgment exists and the debtor is not paying, but does not have a clear picture of what the debtor owns or where. This is where an asset recovery lawyer or judgment enforcement attorney performs the investigative function that precedes enforcement strategy.

Assets of potential relevance include bank accounts and investment portfolios, real estate, company shares and ownership interests, business operations, vessels and aircraft, receivables, intellectual property, and beneficial interests under trust or similar structures. The challenge is that significant assets are often not held in the debtor’s personal name. They sit within companies, held through nominees, or structured in ways that require investigation before the ownership picture becomes clear.

Our article on asset tracing in offshore jurisdictions covers the methods and legal tools available for following assets through corporate and financial structures, including the tracing techniques applicable where funds or ownership interests have been moved through layers of entities.

Lawful asset tracing does not mean unrestricted access to confidential banking or corporate information. The methods available depend on the jurisdiction, the facts, and in many cases the prior involvement of a court. But a judgment enforcement attorney who understands both the investigative options and their legal limitations can build a picture of where recoverable assets are located far more efficiently than a creditor working alone.

5. Assets Appear to Have Been Moved or May Be Dissipated

Where there are signs that the debtor is moving assets, the time available to act before those assets become inaccessible narrows quickly. Warning signs include sudden transfers of real estate or company shares to connected parties, rapid movement of funds between accounts or jurisdictions, sale of significant assets at or shortly after judgment, changes in corporate ownership that appear designed to distance the debtor from valuable property, and efforts to move assets to jurisdictions where enforcement is more difficult.

When Might a Freezing Injunction Be Relevant?

Freezing relief is designed to preserve assets while enforcement or proceedings are pending. Its purpose is not to give the creditor ownership of the assets or to satisfy the judgment in advance: it is to prevent the debtor from dissipating or removing specific assets so that they remain available if enforcement succeeds.

Obtaining a freezing injunction requires more than holding a judgment. The applicant must demonstrate a real risk that assets will be dissipated before enforcement can take place, a sufficient legal basis for the order, and that the balance of convenience supports granting it. The existing judgment is relevant evidence but does not create an automatic entitlement to preservation relief.

Our guide to freezing assets in The Bahamas explains the applicable legal thresholds and how freezing applications work in the Bahamian context, including the circumstances in which applications can be made on an urgent basis.

6. The Debtor Owns Offshore Companies

The presence of offshore company structures in the debtor’s financial picture requires careful analysis before any enforcement strategy is designed. The central legal distinction is this: a debtor who owns shares in a company does not personally own that company’s assets. The assets belong to the company as a separate legal entity. Enforcement against the debtor’s shares is different from enforcement against the company’s assets, and enforcement against the company’s assets requires claims against the company itself.

What a judgment enforcement attorney may need to investigate in these circumstances includes the nature and extent of the debtor’s shareholding, the corporate records and constitutional documents of the company, any intercompany transactions that may have moved value between entities, whether the debtor exercised effective control over company assets in a way that affects the analysis, and whether the structure raises questions about beneficial ownership that have enforcement implications.

None of this means offshore companies are inherently problematic. International businesses routinely use corporate structures for entirely legitimate commercial and planning reasons. But the ownership analysis must be done carefully, and assumptions that the debtor’s connection to a company automatically makes its assets available to creditors will produce incorrect conclusions.

7. Trusts Are Involved

Where the debtor is connected to a trust structure, either as settlor, beneficiary, trustee, protector, or through a company owned by a trust, the enforcement analysis becomes more complex still.

A settlor who has properly transferred assets to a trust no longer personally owns those assets: the trustee holds them. A discretionary beneficiary has no fixed entitlement to any specific trust asset. These are not technicalities designed to frustrate creditors: they reflect the genuine legal character of trust arrangements. But they mean that the creditor cannot assume trust property is available to satisfy a personal judgment against a person connected to the trust without a detailed analysis of the specific structure, the governing law, and the applicable rules for challenging trust arrangements in the relevant jurisdiction.

Where there is evidence that assets were transferred into a trust specifically to frustrate a known creditor, or that a trust is being used in a way that does not reflect a genuine separation of ownership, different legal arguments may become available. Our article on trust disputes involving trustees and beneficiaries addresses the circumstances in which trust structures can be challenged, which is a distinct exercise from ordinary judgment enforcement.

8. Banks or Third Parties May Hold Information About the Assets

Some enforcement situations involve not a lack of assets but a lack of information about where those assets are or where they went. A debtor who received substantial commercial payments may have passed those funds through accounts and entities whose identity the creditor cannot readily establish. A debtor who previously held real estate or company interests may have transferred them to connected parties whose connection is not immediately apparent from public records.

In these circumstances, court-ordered disclosure mechanisms may potentially assist. Where a third party such as a bank, corporate service provider, registered agent, or other intermediary has become innocently involved in transactions connected to the debtor or the underlying dispute, and holds information that is necessary for the creditor to identify wrongdoers, trace assets, or pursue enforcement, a court may order that third party to disclose what it knows.

This is the territory of Norwich Pharmacal Orders, which allow a court to compel an innocent third party who has been mixed up in wrongdoing to provide information enabling the wronged party to seek justice. These are not unlimited disclosure tools, and they require the applicant to satisfy specific legal requirements before an order is granted. But in the right circumstances, a disclosure order directed at a financial institution or corporate administrator can provide the critical piece of information that an enforcement strategy needs.

9. Multiple Jurisdictions Are Involved

Many significant judgment enforcement matters involve more than one country. A judgment obtained in the United States, against a debtor resident in one country, with a Bahamian holding company, a bank account in a second jurisdiction, and real estate in a third, may require coordinated activity across several legal systems simultaneously or in a carefully planned sequence.

No single lawyer can typically conduct every proceeding in every jurisdiction. What an experienced international judgment enforcement attorney provides in this context is the ability to coordinate the overall strategy: determining which jurisdiction to move in first, how to share evidence lawfully between proceedings, how to sequence enforcement steps to avoid prejudicing later applications, how to manage the cost of multi-jurisdiction activity against the expected recovery, and how to work effectively with local counsel in each relevant country.

The practical question is not just what is legally possible in each jurisdiction. It is which combination of enforcement actions, in which sequence, is most likely to produce actual recovery within a commercially rational timeframe and cost.

Why Local Counsel Matters in Foreign Judgment Enforcement

The lawyer who obtained the original judgment understands the underlying facts, the pleadings, and the legal arguments that produced the outcome. That understanding is valuable. It does not, by itself, equip that lawyer to conduct enforcement proceedings in a foreign jurisdiction where they may not be admitted to practice, where the recognition procedures differ materially from what they know, and where the enforcement mechanisms available against specific asset types require knowledge of local practice and procedure.

Local counsel in the enforcement jurisdiction brings knowledge of how recognition applications work in that court, what defences the debtor is likely to raise and how courts there have approached them, which enforcement mechanisms are appropriate given the nature of the available assets, what the practical timelines look like, and how to coordinate effectively with the originating legal team.

This is particularly relevant in The Bahamas, where US judgments require a common-law recognition route rather than registration under the statutory framework, where freezing applications carry their own procedural requirements, and where the nature of corporate and trust structures commonly encountered in the jurisdiction requires familiarity with Bahamian company and trust law as well as enforcement procedure.

Our article on when foreign law firms need Bahamian counsel explains how Bahamian local counsel fits into cross-border enforcement and asset recovery matters, including the practical and procedural considerations that determine when local representation becomes necessary.

When Should US Counsel Involve a Bahamas Judgment Enforcement Lawyer?

For US attorneys handling matters where the debtor has connections to The Bahamas, the answer is usually earlier than they think.

The situations that call for involving Bahamian counsel include: the debtor owns assets in The Bahamas, whether directly or through a company; the debtor holds shares in a Bahamian entity; funds may have passed through Bahamian financial institutions or companies; a Bahamian bank, registered agent, or corporate service provider may hold information relevant to the enforcement strategy; urgent preservation measures may be necessary; or related proceedings have already been commenced in The Bahamas.

Engaging Bahamian counsel early allows the creditor to understand, before committing to costly enforcement proceedings, whether there are realistically recoverable assets in The Bahamas, what the applicable recognition route requires, and what procedural timeline is realistic. That analysis shapes the broader enforcement strategy rather than arriving as a surprise when the matter is already in motion.

ParrisWhittaker’s US judgment enforcement in The Bahamas practice works with US attorneys, in-house counsel, and international law firms as Bahamian local counsel for recognition and enforcement matters, asset tracing, and related preservation applications. The aim is to complement the work of the originating legal team rather than to displace it.

Judgment Collection Attorney vs Judgment Enforcement Attorney vs Asset Recovery Lawyer

These terms appear interchangeably in practice, and the distinctions are more about emphasis than formal professional categories.

A judgment collection attorney is often used to describe counsel focused on the practical collection of unpaid judgments using available domestic enforcement procedures: garnishments, levies, charging orders, and similar mechanisms.

A judgment enforcement attorney typically describes counsel handling the legal procedures required to enforce an existing judgment, potentially including recognition in a foreign jurisdiction and the coordination of cross-border enforcement activity.

An asset recovery lawyer becomes the relevant description when identifying, tracing, preserving, or recovering specific assets forms the central function of the engagement, particularly where assets have been moved or concealed through complex structures.

In practice, sophisticated cross-border matters require all three functions, often from the same team. A creditor whose debtor has moved assets through offshore companies into trusts across multiple jurisdictions needs counsel who can trace those assets, investigate the corporate and trust structures, obtain recognition of the original judgment, secure preservation relief where necessary, and deploy enforcement mechanisms to actually recover value. The label matters less than whether the lawyer understands and can handle the full process.

What Should You Bring to Your First Meeting With an Enforcement Lawyer?

Gathering the right material before the initial conversation saves time and allows counsel to give a more informed early assessment of the enforcement prospects.

Useful material to bring includes the original judgment and any supporting court orders, details of any appeals and their current status, information identifying the judgment debtor including any known addresses, corporate affiliations, and financial institution relationships, details of any assets already known or suspected, evidence of recent asset transfers or corporate changes that may be relevant, any communications with the debtor about payment, any existing settlement discussions or agreements, information about other creditors who may have claims against the same debtor, and details of any existing security interests that may affect priority.

The more complete the initial picture, the more efficiently counsel can assess which jurisdictions matter, what investigative steps are needed, and what an enforcement strategy should look like.

What Should a Judgment Enforcement Strategy Consider?

The right question for enforcement counsel to start with is not “what legal proceedings can we commence?” It is “what are we realistically going to recover, and through which route?”

A well-constructed enforcement strategy assesses the size of the judgment against the value of identifiable assets, the strength of the evidence connecting those assets to the debtor, their liquidity and accessibility, whether secured creditors or competing judgment creditors have priority claims, the realistic cost of enforcement proceedings in each relevant jurisdiction, the risk of the debtor successfully opposing recognition, the timeline to completion, the risk of dissipation if proceedings are delayed, and whether a negotiated settlement at a reduced figure might produce a better commercial outcome than multi-year enforcement litigation.

A $3 million judgment against a debtor with $3.2 million of identifiable assets across multiple jurisdictions may require $1.5 million of enforcement costs and two years of proceedings to recover. A negotiated settlement at $1.8 million, paid within months, may represent the superior commercial outcome. An enforcement lawyer who understands only litigation and not recovery will not have that conversation.

How Much Does International Judgment Enforcement Cost?

There is no meaningful universal figure, and any specific number given before the matter is properly assessed should be treated sceptically.

Enforcement costs depend on the number of jurisdictions involved, whether recognition proceedings are contested, the extent of asset tracing required, whether urgent injunction applications are necessary, the nature and location of the assets targeted, whether the debtor mounts procedural challenges or appeals, and whether disclosure proceedings are needed in addition to enforcement.

What can be said is that the cost of enforcement should be assessed against the likely recovery before significant resources are committed. Enforcement against liquid assets in a well-organised jurisdiction with an efficient court system looks very different from multi-year contested proceedings across three jurisdictions involving corporate and trust structures, disputed beneficial ownership, and a debtor with the resources to fight at every stage.

How Long Does Foreign Judgment Enforcement Take?

The timeline depends on the same variables as the cost analysis. An uncontested recognition and enforcement proceeding against a cooperative debtor or clearly accessible assets can be completed relatively quickly. A contested multi-jurisdiction matter involving disputed asset ownership, corporate structures, and appeals at every stage can run for years.

The most common timing risk is not the court process itself: it is delay in beginning the investigation and enforcement activity. The period immediately after judgment, when the debtor’s attention is focused on the outcome and before they have had the opportunity to reorganise their financial affairs, is often the most favourable window for enforcement action.

Common Mistakes When Engaging Counsel for Judgment Recovery

Waiting until assets have already been moved. Asset investigation and enforcement planning should begin as soon as it is clear that voluntary payment is not forthcoming, not after the debtor has had months to restructure.

Assuming the original litigation lawyer can enforce everywhere. Originating counsel may be excellent lawyers who are simply not admitted or experienced in the jurisdiction where the assets are located.

Starting proceedings before confirming valuable assets exist. Enforcement against an asset-light debtor is expensive litigation with nothing at the end of it.

Treating company assets as personal assets of the debtor. A debtor’s connection to a company does not make the company’s assets the debtor’s property.

Pursuing every jurisdiction instead of prioritising recovery. Multi-jurisdiction enforcement multiplies costs and management burden. Strategy should direct resources to where recovery is most realistic.

Focusing only on the judgment amount. The size of the judgment is the ceiling on recovery, not the floor. What matters for strategy is the value of recoverable assets, not the number on the judgment.

Ignoring settlement when it may produce a better commercial outcome. The purpose of enforcement activity is recovery, not litigation. A realistic settlement offer that delivers substantial recovery quickly may be worth more than winning every procedural battle over several years.

Choosing a Judgment Enforcement Attorney

The criteria worth applying when selecting enforcement counsel for a cross-border matter include experience in foreign judgment recognition proceedings, familiarity with asset tracing methods and their legal limitations, experience in obtaining freezing or preservation relief, knowledge of corporate and trust structures as they affect ownership analysis, the ability to work effectively with foreign counsel where multiple jurisdictions are involved, and a demonstrated understanding of the commercial objective, which is recovery, not just legal process.

A lawyer who can explain both what is legally possible and what is commercially rational, and who gives a frank assessment of the likely cost, timeline, and recovery prospects before significant resources are committed, is providing better service than one who proceeds without that analysis.

Parris Whittaker and Cross-Border Judgment Enforcement in The Bahamas

ParrisWhittaker’s published experience includes foreign and US judgment recognition and enforcement, asset tracing, freezing orders, commercial litigation, trust disputes, and cross-border matters involving Bahamian entities, companies, and financial institutions.

Jacy Whittaker, founding partner, has specific published experience in asset tracing, freezing orders, and enforcement of US judgments, making her practice directly relevant to the kind of multi-element international enforcement matter described throughout this article. Connecting the work to an identifiable lawyer with published experience in these specific areas is more useful than general descriptions of the firm’s capabilities.

When to Speak to Bahamian Counsel

A creditor or overseas legal team should consider engaging Bahamian counsel where any of the following apply: a foreign debtor has significant assets in The Bahamas; a US judgment needs recognition and enforcement in The Bahamas; Bahamian companies are involved in the debtor’s financial structure; ownership of assets requires investigation; there is evidence that assets are being moved; Bahamian court relief, including freezing orders or disclosure, may be necessary; or foreign counsel needs Bahamian local litigation support.

ParrisWhittaker advises judgment creditors, international businesses, and overseas counsel on foreign judgment recognition and enforcement in The Bahamas, asset tracing, preservation applications, and the full range of enforcement and asset recovery proceedings before the Bahamian courts. We work alongside originating counsel as local Bahamian representation, providing the jurisdictional expertise that cross-border enforcement requires without displacing the relationship the creditor has with their existing legal team.

Contact ParrisWhittaker to discuss whether Bahamian enforcement proceedings are appropriate for your matter.

Frequently Asked Questions

What does a judgment enforcement attorney do?

A judgment enforcement attorney handles the legal process of converting a court judgment into actual recovery. That may involve reviewing the judgment, investigating where the debtor’s assets are located, determining which jurisdictions are involved, obtaining recognition in the enforcement jurisdiction, pursuing preservation relief if assets are at risk, and deploying enforcement mechanisms to recover value.

When should I hire a judgment enforcement attorney?

Where a debtor refuses to pay voluntarily, where assets are located in another country, where recognition proceedings are required, where asset ownership is complex or unclear, where there is a risk of dissipation, or where multiple jurisdictions are involved. The sooner enforcement counsel is engaged after payment defaults, the more options remain available.

What is the difference between a judgment collection attorney and a judgment enforcement attorney?

The terms overlap substantially and there is no formal distinction. Judgment collection tends to describe domestic enforcement using available legal mechanisms. Judgment enforcement is more commonly used in cross-border contexts involving recognition proceedings and foreign enforcement. Asset recovery lawyer is used where investigation, tracing, and recovery of specific assets is the central function. In practice, complex international matters require all three functions.

Can a lawyer find a judgment debtor’s assets?

Enforcement counsel can investigate asset ownership through available lawful methods including analysis of public records, corporate registries, court processes, and in appropriate cases court-ordered disclosure. The available methods depend on the jurisdiction and the specific facts of the matter.

Can a US judgment be enforced in another country?

Potentially, subject to the recognition and enforcement laws of the destination jurisdiction. US judgments are not automatically enforceable abroad. The creditor must satisfy the recognition requirements of the country where enforcement is sought, which vary materially between jurisdictions.

Can a US judgment be enforced in The Bahamas?

US judgments fall outside the statutory registration framework under the Bahamas Reciprocal Enforcement of Judgments Act 1924. Enforcement requires common-law recognition proceedings commenced in the Bahamian Supreme Court. ParrisWhittaker’s US judgment enforcement in The Bahamas service advises on this process.

Do I need a lawyer in the country where the debtor’s assets are located?

In almost all cases where recognition or enforcement proceedings are required in a foreign jurisdiction, yes. Local counsel brings knowledge of the applicable procedures, limitation periods, defences, enforcement mechanisms, and practical realities of the local courts that originating counsel in another country cannot replicate.

Can an enforcement lawyer freeze a debtor’s assets?

Enforcement counsel can apply for freezing or preservation relief where the applicable legal requirements are satisfied. Freezing orders are not automatic following judgment. They require the applicant to demonstrate a real risk of dissipation and satisfy other legal thresholds specific to the jurisdiction.

Can assets owned by the debtor’s company be seized?

Not automatically. Assets legally owned by a company belong to that company as a separate legal entity. A judgment against an individual shareholder does not directly make the company’s assets available for enforcement. The creditor may be able to enforce against the debtor’s shares, and in specific circumstances may have arguments that allow them to reach underlying assets, but these require careful legal analysis.

How long does international judgment enforcement take?

Timing depends on the jurisdiction, whether recognition is contested, the nature and location of the assets, whether urgent applications are required, and the debtor’s level of opposition at each stage. A straightforward uncontested matter can resolve relatively quickly. A contested multi-jurisdiction matter involving complex ownership disputes can take considerably longer.

How much does judgment enforcement cost?

There is no universal figure. Cost depends on the number of jurisdictions, the complexity of proceedings, whether recognition is opposed, the extent of asset tracing required, and the nature of the enforcement mechanisms deployed. A realistic cost analysis weighed against likely recovery should form part of the early enforcement assessment.