Nowhere Left to Hide: Quinn Emanuel's Justin Michaelson and Simon Camilleri on the Evolving Reach of the Worldwide Freezing Order

Quinn Emanuel Partner Justin Michaelson and Of Counsel Simon Camilleri's chapter for Global Legal Insights – Litigation & Dispute Resolution 2026 takes on one of English civil litigation's most formidable weapons, memorably dubbed one of the law's "nuclear weapons" in the case law: the worldwide freezing order.

Their chapter, "Recent developments in worldwide freezing orders – the decisions in Lakatamia, Gilbert and Petrichor" is a close study of the fifty-year-old jurisdiction's outer limits, tracing how far a freezing order's reach can extend beyond the defendant themselves, to foreign parties who help them evade it and to the assets of people who are not parties to the case at all.

In their chapter, they examine three recent decisions to show how courts are expanding the practical effectiveness of the freezing order as a tool for cross-border enforcement, while continuing to insist on strict procedural discipline in how it is obtained.

Among the takeaways:

• A foreign lawyer, banker, or other intermediary who knowingly helps a defendant move assets in breach of an English freezing order is not shielded from civil liability simply because their own conduct was lawful where they carried it out, or because they cannot be held in contempt of an English court order from abroad.
• Claimants seeking to freeze assets held by non-parties overseas – family members, nominees, or corporate vehicles used to obscure a defendant's true wealth – must still clear strict jurisdictional hurdles, and timing can be decisive: once judgment has already been entered against the underlying defendant, certain routes to reach those assets can close off entirely.
• The courts have also had to grapple with the tests that apply once a freezing order is sought after judgment has already been obtained, rather than before or during the underlying claim.
• Together, the decisions reflect a jurisdiction still very much in motion, offering claimants new avenues for recovering assets internationally while sharpening the procedural rules that govern how those avenues can be used.

Read Justin and Simon's chapter here.