When a company structured under European law begins operating in the United States, the legal assumptions it relies on do not always hold. Contractual provisions that are enforceable in one jurisdiction may be interpreted differently in another, and regulatory expectations can shift depending on where operations are based. Inès Lassalle’s practice focuses on these points of friction, advising clients on structuring their activities to remain consistent across the U.S. and French legal systems. Dual-qualified and admitted to practice in California and France, she received the 2025 Global Recognition Award in law for her work in cross-border legal structuring and international advisory services.
In global transactions, these differences are not theoretical. A contractual clause drafted under U.S. assumptions may not produce the same legal effect under French law, particularly in areas such as liability, termination rights, or dispute resolution. Similarly, regulatory compliance obligations, especially in sectors such as technology or health, may overlap in intent but diverge in execution. Lassalle’s work involves identifying these inconsistencies early—for example, where contractual liability provisions, dispute resolution clauses, or data protection obligations may be interpreted differently across jurisdictions—and adapting agreements and organizing business operations to ensure they remain enforceable and compliant under both legal systems.
As cross-border business activity expands, differences between legal systems remain a central source of legal risk for internationally active companies. Addressing these risks requires compliance with multiple jurisdictions and structuring operations in a way that remains coherent across them. These challenges are addressed by aligning agreements, entity structures, and compliance frameworks so that business operations remain consistent and enforceable across the U.S. and French legal systems.
During the interview with Lassalle, she noted that these challenges frequently arise at the contractual stage, particularly when U.S.-style liability clauses or dispute-resolution mechanisms do not translate directly into French or broader European legal frameworks.
For example, she described situations in which U.S.-drafted agreements included liability caps or indemnification provisions that would not be interpreted in the same way under French law, requiring adjustments to ensure that risk allocation remained effective across jurisdictions.
She also noted that similar challenges arise when European companies expand into the U.S. market, particularly in aligning data protection practices or employment structures with local regulatory expectations while maintaining consistency with European requirements. In such cases, her work involves adapting contractual provisions, revising risk allocation mechanisms, and structuring agreements to remain effective under legal systems, while ensuring that regulatory obligations—such as data protection or employment requirements—are consistently addressed across jurisdictions.
In practice, this work takes shape in how agreements are drafted, entities are organized, and compliance obligations are managed across jurisdictions. The objective is to ensure that these elements operate consistently under U.S. and French law, reducing the risk of conflicting legal interpretations and supporting the continuity of cross-border business operations.
