Skip to content

Menu

Greenberg Traurig, LLP logo
HomeAboutNewsPracticesContact
Search
Close

GT London Law Blog

Legal Advisers for a Changing World

No Way Out: The Service Out Gap for Freezing Orders Supporting English Judgments

Judge's gavel, book and scales on wooden table against flag of United Kingdom-Shutterstock_2680090199
By Claire Broadbelt, Stephanie Silverston, Johnny Shearman & Maisie Stewart on October 7, 2026
Posted in account freezing order, Business Disputes, Featured, GT Alert, Litigation

A freezing order may be one of the most powerful tools available to a creditor in the courts of England and Wales. In simple terms, a freezing order stops a person from moving, hiding, or spending their assets, up to a set value, so that a judgment can later be enforced against them. A worldwide freezing order (WFO) extends that protection to assets anywhere in the world.

However, a freezing order is only as good as the court’s power over the person it targets. Where that person is outside England and Wales, the claimant usually needs the court’s permission to serve the application on them abroad. Permission may only be given if the claim fits within one of the “gateways” listed in paragraph 3.1 of Practice Direction 6B to the Civil Procedure Rules (PD 6B).

In Gilbert & Anor v Broadoak Private Finance Ltd [2026] EWCA Civ 1172, the Court of Appeal confirmed that none of the three gateways the claimants relied upon permitted service out for a free-standing freezing order application brought to assist the enforcement of a judgment of the courts of England and Wales. A strong case on the merits is not enough if the court has no jurisdiction over the respondent. The decision also highlights the difference between domestic and foreign judgments, as there is a gateway enabling an application for a freezing order intended to assist in the enforcement of a foreign judgment to be served abroad.

Continue reading the full GT Alert.

Tags: GT Insight
Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Claire Broadbelt Claire Broadbelt

Claire Broadbelt, Co-Chair of the London Civil Fraud & Business Disputes Practice, represents clients on multi-jurisdictional civil fraud matters, both pursuing and defending complex claims. Her cases (which have included some of the highest value cases ever before the English High Court) often…

Claire Broadbelt, Co-Chair of the London Civil Fraud & Business Disputes Practice, represents clients on multi-jurisdictional civil fraud matters, both pursuing and defending complex claims. Her cases (which have included some of the highest value cases ever before the English High Court) often involve serious allegations of fraud or misconduct, including the diversion of business opportunities, claims of deceit, breach of confidence, breaches of fiduciary duty, conspiracy, bribery, and secret profits. She regularly handles matters which include worldwide asset-tracing and recovery, freezing and search orders, and other associated injunctions. She advises clients across a wide range of sectors including banking and finance, commodities trading, IT, retail, and property.

Read more about Claire BroadbeltClaire's Linkedin Profile
Show more Show less
Photo of Stephanie Silverston Stephanie Silverston

Stephanie Silverston is an experienced litigator focusing on commercial litigation, civil fraud, and contentious insolvency, often as part of complex multijurisdictional disputes. She represents a wide range of clients including HNW individuals, businesses, and insolvency practitioners on commercial advisory matters, shareholder disputes, breach…

Stephanie Silverston is an experienced litigator focusing on commercial litigation, civil fraud, and contentious insolvency, often as part of complex multijurisdictional disputes. She represents a wide range of clients including HNW individuals, businesses, and insolvency practitioners on commercial advisory matters, shareholder disputes, breach of fiduciary duty claims, unfair prejudice petitions, claims under the Insolvency Act 1986, and matters involving misrepresentation.

Stephanie has broad experience working on cases involving fraud, internal investigations, and crisis management, and the interplay between parallel civil and criminal proceedings. Her experience includes bringing and responding to freezing orders and proprietary injunctions, obtaining Norwich Pharmacal Orders, and dealing with asset disclosure and asset protection issues. She also acts for clients regarding family matters and trust disputes.

Stephanie assists clients in other jurisdictions seeking cross-border evidence, both obtaining or resisting letters of request for depositions and disclosure in support of foreign proceedings and enforcement matters.

Read more about Stephanie SilverstonStephanie's Linkedin Profile
Show more Show less
Photo of Johnny Shearman Johnny Shearman

Johnny is a dispute resolution lawyer and has gained deep experience in handling a broad spectrum of domestic and international disputes. Prior to joining Greenberg Traurig, Johnny held management positions in two leading specialist dispute resolution firms in London.

Johnny has been ranked…

Johnny is a dispute resolution lawyer and has gained deep experience in handling a broad spectrum of domestic and international disputes. Prior to joining Greenberg Traurig, Johnny held management positions in two leading specialist dispute resolution firms in London.

Johnny has been ranked as Recommended Lawyer for Banking Litigation in The Legal 500 UK 2022 being described as “highly recommended” and “engaging and very proactive“. He has worked on some of the highest profile cases in the country including those featured in The Lawyer’s “Top 20 Cases of the Year”.

His legal knowledge encompasses complex contractual and tortious disputes, civil fraud and asset recovery, banking and professional negligence litigation, and contentious insolvency matters. His experience includes disputes at all levels from County Court to Supreme Court proceedings, as well as international arbitration.

He is the co-author of International E-Discovery: A Global Handbook of Law and Technology, Second Edition and he routinely comments on civil procedure and legal developments.

He is also an elected member of The Law Society Council of England and Wales, representing members of the profession with between six and 12 years post-qualification experience.

Johnny was a featured guest on the Legally Speaking Podcast (season 3, episode 9).

Read more about Johnny Shearman
Show more Show less
Photo of Maisie Stewart Maisie Stewart

Maisie is a dispute resolution lawyer and has worked on complex contentious cases of significant value across a number of sectors, including financial services, insurance and aviation.

Maisie has acted on a number of high profile domestic and international disputes in the Commercial…

Maisie is a dispute resolution lawyer and has worked on complex contentious cases of significant value across a number of sectors, including financial services, insurance and aviation.

Maisie has acted on a number of high profile domestic and international disputes in the Commercial Court and Financial List. She has also worked on regulatory investigations, defending clients in investigations concerning financial crime controls and market manipulation, and has experience of contentious restructuring and insolvency matters.

Maisie also has an interest in ESG matters, specifically litigation and regulatory risks for financial services clients, and, prior to joining Greenberg Traurig, she regularly commented on developments in this area.

Read more about Maisie Stewart
Show more Show less
Related Posts
WhiteCollar_Proposal
Cleaning House: The UK’s Companies House Releases Third Progress Report on ECCTA 2023
July 13, 2026
WhiteCollar_Proposal
Outlook 2026: UK Civil Fraud & Business Disputes
January 28, 2026
London2
UK Court Grapples with Cryptocurrency Preservation and Enforcement Issues
August 14, 2023

About

The GT London Law Blog analyzes English legal matters. Posts will include insight on legislative and regulatory changes, recent case law and business trends, for those operating in, or considering operating in, the UK.

Read More....

Stay Connected

Facebook LinkedIn RSS Twitter
Subscribe

Topics

Blog Authors Show/Hide

  • Erik de Bie
  • Darren Abernethy
  • Stephen Abram
  • Ashia D. Adams
  • Lauren Alderson ˘
  • Sophie Allen
  • Virginia Allen
  • Greta Barkle
  • Ian Bean
  • Dr. Kati Beckmann
  • Leith Ben Ammar
  • Sara Berendsen
  • Clea Bigelow-Nuttall FCIArb
  • Matthew Birchall
  • Hannah Blom-Cooper
  • Marijn Bodelier
  • Kara M. Bombach
  • Katharine Bond
  • Cyril T. Brennan
  • Claire Broadbelt
  • Giuseppe Bulgarini d'Elci
  • Adam Cain
  • Charles Edward Case
  • Andrew Caunt
  • Rupert Cheetham
  • Emily Chen ˘
  • Addiped Cheng
  • Greenberg Traurig
  • Gavin Costelloe
  • Steven Cowins
  • Steven Cowins
  • Manish Das
  • Greenberg Traurig, LLP
  • Samantha De Souza
  • Kelly Dobbs Bunting
  • Sonali Dohale
  • Tim Dolan
  • Sylvie A. Durham
  • Greenberg Traurig
  • Ben Eaton
  • Simon Elliott
  • Christoph Enaux
  • Elliott Fellowes
  • Paul Ferak
  • Meira Ferziger ^
  • Matthew Finnie ‡
  • Dorothee Fischer-Appelt
  • David Fitzgerald
  • Ailish Foad
  • Elizabeth Fox
  • Kyle R. Freeny
  • Robert Gago
  • Edoardo Gambaro
  • Jessica Ganagasegaran
  • Kathryn Garbett
  • Samuel Garcia Nelen
  • Charles O. George
  • Michael P. Goldberg
  • Anna Goodes ˘
  • Alan R. Greenfield
  • Anna Halas-Krawczyk
  • Gareth Hall
  • Matt Hancock
  • Elizabeth (Liz) Harding
  • Robert Hardy
  • Simon Harms
  • Michiko Head
  • Greenberg Traurig
  • Tom Hilton ˘
  • Bethany Histed
  • Carol Hopper
  • John Houghton
  • Richard Hughes
  • Maymunah Hussain ˘
  • Graham Iversen
  • Christopher Ives*
  • Oleskii Izotov
  • Ian Jack
  • Jinan Jawad
  • Clive Jones
  • Jakob Methodius Jürgensen
  • Jelmer Kalisvaart
  • Tina Kang
  • Mehmet Karagoz
  • Mohammed Khamisa QC
  • Harshita Khurana‡
  • Sophia Kotsianou
  • Michael M. Krauss
  • Shashank Krishna
  • Russell Lamb
  • Greenberg Traurig, LLP
  • Patrick G. Lilly ‡
  • Kate Martin
  • Danielle L. Martin
  • Graeme McLellan
  • Rebecca Meads
  • Thédoor Melchers
  • Nazmul Miah
  • Ewen Mitchell
  • Amy Moore˘
  • Irina Morozova
  • James Mountain
  • Kevin Mulligan ‡
  • Greenberg Traurig, LLP
  • Jack Myers˘
  • Arleen A. Nand
  • Julia Nefedovica
  • Susan E. D. Neuberg
  • Thai Nguyen
  • Sajidah Norat
  • Mollie O'Connor ‡
  • Anne-Marie Ottaway
  • Partha S. Pal
  • Christiana Papanastasiou ˘
  • Alexandra Percy ˘
  • Chantal Phillips
  • Eleanor Pike
  • Adam Potter
  • Matthew Priday
  • Greenberg Traurig, LLP
  • Jo Rickards
  • Florian Rösch
  • Halimah Sattar
  • Sarah C. Schenker
  • Sabine Schoute
  • Cate Sharp
  • Mikaela Shaw Masoudpour
  • Johnny Shearman
  • Martin Shobbrook
  • Stephanie Silverston
  • Marc E. Snell
  • Marc E. Snell
  • Helen Sotillo
  • Oscar Stephens
  • Maisie Stewart
  • Chazz Sutherland
  • Alex Swan
  • Annabel Thomas
  • Thomas Timmermans
  • Alex Tostevin
  • Greenberg Traurig
  • Stephen C. Tupper
  • Kirsty Turner
  • Robert Turner
  • Thilo Ulrich
  • Hans Urlus
  • Jena M. Valdetero
  • Barry Vitou
  • Bas Vletter
  • John Voorhees
  • Francisco J. Vélez ‡
  • Lilian Welling-Steffens
  • Rachel Whittaker
  • Sue Wilson
  • Ailish E. Winch
  • Gabi Wong ˘
  • Masoud Zabeti
  • Peter Zingel
  • Wietse de Jong
  • Emilie van Hasselt
  • Marie-José van der Heijden
  • Dorothee von Einem
GT Law Blogs

Archives

Recent Posts

  • No Way Out: The Service Out Gap for Freezing Orders Supporting English Judgments
  • UK Supreme Court Clarifies What Directors’ Duty of ‘Good Faith’ Requires
  • Personal Guarantees in UK Real Estate Finance Transactions – Considerations for Lenders
  • Cleaning House: The UK’s Companies House Releases Third Progress Report on ECCTA 2023
  • UK Financial Conduct Authority Consults on Tougher Penalty Framework

GT London Law Blog

Greenberg Traurig, LLP logo
Facebook LinkedIn RSS Twitter
Privacy PolicyEuropean Offices Privacy NoticeDisclaimer

About Greenberg Traurig

Greenberg Traurig, LLP has more than 3,200 lawyers across 51 locations in the United States, Europe, the Middle East, Latin America, and Asia. The firm’s broad geographic and practice range enables the delivery of innovative and strategic legal services across borders and industries. Recognized as a 2025 BTI “Best of the Best Recommended Law Firm” by general counsel for trust and relationship management, Greenberg Traurig is consistently ranked among the top firms on the Am Law Global 100, NLJ 500, and Law360 400. Greenberg Traurig is also known for its philanthropic giving, culture, innovation, and pro bono work. Web: www.gtlaw.com.

Copyright © 2026, Greenberg Traurig, LLP. All Rights Reserved.
Law blog design & platform by LexBlog LexBlog Logo