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Desmarais & Anor v Misbourne Investment Corporation & Ors [2025] EWHC 813 (Comm) (04 April 2025)

Source: Open mirrored case · Original bailii.org

Sanctions — Geo —

Executive Summary

  • The case concerns a dispute over derivative claims related to Misbourne Investment Corporation, a Liberian-registered company forming part of the estate of the late Philippos Embiricos Coumoundouros.
  • Claimants Olivier Desmarais and Adriana Embiricos Coumoundouros seek permission to bring derivative claims on behalf of Misbourne against Green Services International GSI Ltd (GSI) and others.
  • GSI, controlled by Libra Holdings Limited, demanded repayment of a €72 million loan from Misbourne, which claimants allege is not genuine.
  • The court must decide if there is a prima facie case to grant permission for derivative claims; the application was dismissed at the first stage due to lack of proper boundaries for such claims.
  • The judgment clarifies procedural principles for derivative claims involving foreign companies under CPR 19.17 and common law.

Sanctions Highlights

  • — No sanctions implications identified in the case.

Emerging Risks

  • Potential misuse of corporate governance mechanisms (e.g., director resignations) to trigger aggressive debt enforcement.
  • Risk of intra-family and cross-jurisdictional corporate disputes escalating into protracted litigation.
  • Challenges in derivative claims involving foreign companies may limit remedies for shareholders or beneficiaries.
  • Possible reputational risks for entities involved in opaque loan arrangements and contested corporate control.

Geopolitical Impact

  • — No geopolitical significance or country-level impact noted.

Economic Intelligence

  • The disputed loan amount exceeds €72 million, indicating significant financial stakes within the maritime/shipping sector.
  • The case highlights complexities in enforcing or disputing large inter-company loans across jurisdictions (Liberia, Cyprus, Bermuda).
  • The litigation may affect the operational control and financial stability of Misbourne Investment Corporation.
  • The involvement of multiple offshore entities underscores ongoing challenges in transparency and governance in international maritime investments.

Strategic Recommendations

  • Parties should ensure clarity and documentation of inter-company loans to avoid disputes and claims of non-genuineness.
  • Legal strategies involving derivative claims against foreign companies must carefully consider procedural thresholds under CPR 19.17 and common law.
  • Stakeholders should monitor director appointments and resignations as potential triggers for creditor actions.
  • Consider alternative dispute resolution mechanisms to mitigate protracted litigation risks in complex family and corporate disputes.
  • Enhance due diligence on offshore entities’ governance structures to anticipate and manage derivative claim risks.

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**Source Notes:**

*Sanctions Intelligence Digest* — [https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/813.txt](https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/813.txt)

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