The U.S. Supreme Court's recent decision in Kiobel v. Royal Dutch Petroleum1 upholding the dismissal of an Alien Tort Claims Act (ATCA) suit, left a great deal unanswered.  The Kiobel decision did, however, limit the potential for future ATCA claims by applying a strong presumption against that statute's extraterritorial application.  There have since been some mixed appellate court decisions regarding the statute's extraterritorial application,2 but a recent decision by the U.S. Court of Appeals for the Ninth Circuit may...

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DS-Concept Factoring, Inc., a global commercial finance company specializing in international non-recourse factoring, has provided a $3 million export accounts receivable facility to an automobile parts manufacturer in India. The client, who provides truck and tractor parts to major automobile manufacturers in the USA, and Europe, is implementing this non-recourse factoring facility to free up their local borrowing facilities so they can reinvest in additional inventory and capital expenditure to accommodate growing sales. By working with DS-Concept, the client can now replace the...

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