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Multi-jurisdiction asset-based lending facility with borrowing base spanning inventory and receivables across Sweden, Norway, and Denmark supporting manufacturing carve-out.
A Nordic-focused private equity fund acquired a regional manufacturing business operating across three countries from a European industrial group, requiring working capital facility to support seasonal inventory and receivables cycles.
Key complexity factors included:
We structured a €120M revolving asset-based lending facility with aggregated borrowing base across three Nordic jurisdictions. The solution included:
Revolving credit facility with cross-border borrowing base mechanics, eligibility criteria customized for Nordic markets, and overadvance provisions for seasonal working capital.
Swedish law enterprise asset pledge (företagshypotek) with corresponding Norwegian floating charges and Danish company charges, including account control agreements for collection accounts.
ABL/cash flow intercreditor with covenant-lite term loan, establishing priority waterfall, permitted payments, and enforcement standstill provisions.
Weekly borrowing base reporting template with automated ERP integration, dilution tracking, and concentration reserves across customer and jurisdiction limits.
Initial field examinations, inventory appraisals, and receivables aging analysis across all sites
ABL credit agreement drafting, multi-jurisdiction legal due diligence, and borrowing base modeling
Coordinated security documentation under Swedish, Norwegian, and Danish law with local counsel opinions
Facility closing with immediate borrowing base integration and initial drawdown for working capital
The transaction closed successfully, providing the company with flexible working capital facility supporting seasonal business cycles across Nordic operations.
Post-closing benefits:
Our network specializes in complex cross-border financing transactions across multiple jurisdictions and asset classes.
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