Cross-Border Banking & Finance Attorney
Attorney Manny Chahal represents borrowers and lenders in cross-border financing transactions between Canadian financial institutions and properties located in the United States. Over $1.5 billion in cross-border banking and finance transactions, with deep experience structuring loan documentation, parallel security packages, and multi-jurisdictional closing logistics for US-Canada deals — serving as US-side counsel for clients with operations on both sides of the border.
Cross-Border Practice Areas
Sanctions-aware, enforcement-ready international financing transactions.
Canadian Bank Financing of US Properties
Loan documentation and closing for Canadian financial institutions financing US-based commercial real estate acquisitions — covering term sheets, credit agreements, and US-side security perfection.
Cross-Border Lending
US-Canada syndicated loans, multi-jurisdictional security packages, parallel-debt structures, and dual-language documentation between US and Canadian counterparties.
Lender-Side Diligence
Pre-closing diligence support for Canadian banks lending into the US — title review, environmental coordination, lease assignment, and US local-counsel coordination.
Borrower-Side Counsel
Representing US-based property owners and developers obtaining financing from Canadian banks — covenant negotiation, intercreditor structuring, and post-closing compliance.
Multi-Jurisdictional M&A
Carve-outs, share vs. asset deals across borders, foreign-investment review (CFIUS in the US, ICA in Canada), and post-merger integration.
OFAC & Sanctions Compliance
SDN screening, country-based sanctions (Russia, Iran, Cuba, North Korea), 50% rule analysis, and licensing applications.
Cross-Border Compliance Counsel
Third-party due diligence, books-and-records support, and coordinated counsel for international compliance matters affecting US-Canada deal flow — coordinated with specialty counsel where required.
Choice of Law & Forum
Selecting governing law, mandatory vs. permissive forum, NY/Delaware vs. Ontario/Quebec considerations, and enforcement-of-judgments planning.
Foreign Investment Review
CFIUS filings (US), Investment Canada Act notifications and reviews, national-security carve-outs, and mitigation agreements.
Cross-Border Regulatory Authorities
Statutes and regulations driving every cross-border financing transaction.
Cross-Border Deal Process
Sanctions screening, multi-jurisdictional documentation, and coordinated US/Canada closings in lockstep.
Sanctions & KYC Screening
OFAC SDN, EU sanctions, Canadian SEMA/UN Act, beneficial-ownership review, and compliance third-party diligence.
Due Diligence
Title, survey, environmental, and zoning review for US property; coordination with Canadian counsel on parent-level matters.
Documentation & Local Counsel
Governing law, security perfection, parallel debt, currency conversion, and coordinated local-counsel opinions.
Closing & Post-Closing
Funding flow, multi-jurisdictional filings, ongoing sanctions monitoring, and covenant compliance.
Frequently Asked Questions
Why use a Canadian bank to finance US property?
Canadian financial institutions often provide more favorable structures, longer-term banking relationships, and access to currency hedging for clients with operations on both sides of the border. Coordinating US-side legal documentation with Canadian credit agreements requires specialized cross-border counsel.
What is OFAC’s “50 percent rule”?
An entity owned 50% or more (in aggregate) by one or more SDNs is itself blocked, even if not separately listed. Beneficial-ownership analysis is required across complex ownership chains.
Can a Canadian bank perfect a security interest on US property?
Yes — security on US-located property is governed by US law. Mortgages and UCC filings are recorded in the US jurisdiction where the collateral is located. Coordinated US/Canada documentation ensures the lender’s priority is preserved on both sides of the border.
What is CFIUS and when must I file?
CFIUS reviews foreign acquisitions of US businesses with national-security implications. Some “covered transactions” require mandatory filing; many others are voluntary but advisable to avoid post-closing unwinds.
Can I enforce a US judgment in Canada (or vice versa)?
Yes — Canadian common-law provinces enforce US money judgments through reciprocal recognition principles. Michigan’s MCL 600.745 provides a parallel framework. Choice of forum and proper service drive recognition outcomes.
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