French lawyer for US companies: disputes, enforcement, sanctions

Your company is American. Your customer, your distributor, your debtor or your dispute is in France. This page brings together what a US company most often needs from a French lawyer, with links to the detailed analyses published on this site.

Getting paid by a French customer or distributor

An unpaid invoice is first a question of jurisdiction: which court, or which arbitral tribunal, does your contract designate, and under which law? Ending a long-standing relationship with a French distributor also carries a specific risk: French law treats the sudden end of an established commercial relationship as a source of liability when the notice given was too short (Article L. 442-1, II of the French Commercial Code). See international commercial litigation and international contracts.

Enforcing a US judgment in France

There is no treaty between France and the United States on the enforcement of judgments. A US judgment is enforced in France through exequatur proceedings before the French court, which checks three conditions set by the Cour de cassation in Cornelissen (Cass. 1re civ., 20 February 2007, No. 05-14.082): a sufficient link between the dispute and the US court, conformity with French international public policy, and the absence of fraud. Punitive damages are not refused as such, unless they are disproportionate (Cass. 1re civ., 1 December 2010, No. 09-13.303). Details: enforcing a US or English judgment in France and exequatur.

Discovery, sanctions and US tariffs

Setting up or investing in France

Creating a subsidiary or a branch, acquiring a French company, and the prior approval required in sensitive sectors (Article L. 151-3 of the Monetary and Financial Code): see foreign companies in France and foreign investment in France.

A matter in France for your company? Describe the contract, the amounts at stake and where things stand with the French party.

Tell us about your situation

Reply within 24 business hours. Before any work starts, you receive a written fee agreement with an estimate of the budget. The work is carried out in writing and in English.

Matters in this field are handled by Hervé Guyader, avocat at the Paris Bar and Doctor of Law. Page updated on 8 November 2026.

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