text: Iceland Versus Scotland: What Happens When Two Inconsistent Insolvency Regimes Clash? - - UK
  UK: Iceland Versus Scotland: What Happens When Two Inconsistent Insolvency Regimes Clash?
  The Credit Institutions (Reorganisation and Winding up) Regulations 2004 were to be construed to ensure forum shopping was not encouraged;
  The extinguishing of a claim in Icelandic insolvency proceedings relating to one entity (Landsbanki) did not affect the ability to assert a right to set off that same claim in Scottish insolvency proceedings (Heritable).
  Landsbanki Islands hf, and Icelandic bank, was the parent company of a Scottish bank Heritable Bank plc. Both were subject to national regulations implementing Directive 2001/24/EC of 4 April 2001 on the reorganisation and winding up of credit institutions (the "Directive"), which applies to EU Member States and non-EU countries in the EEA, including Iceland. The Directive was implemented in the UK by The Credit Institutions (Reorganisation and Winding up) Regulations 2004 (the "Regulations").