Financial Advisory
Cliffordchance
Full Credential Description
Prosafe SE, a leading owner and operator of marine vessels, faced significant financial challenges, including a US$1.6 billion debt load and a NOK 2.5 billion bond debt amounting to US$278 million. The company required a comprehensive restructuring solution to address its financial obligations and ensure operational continuity. Clifford Chance provided a tailored solution that involved a complex cross-border restructuring process. This included swapping US$1.1 billion of debt for 99% of Prosafe SEs equity, reinstating US$250 million of a US$1 billion credit facility, and extending the maturities of all remaining debts to December 2025. The restructuring utilized Singapore moratoria recognized in Brazil, where the vessels were located, and involved inter-conditional schemes of arrangement in Singapore for both Prosafe SE and its subsidiary, Prosafe Rigs Pte. Ltd. These schemes were sanctioned in October 2021, followed by a parallel Norwegian reconstruction process sanctioned in November 2021. The successful implementation of this restructuring on December 17, 2021, marked a significant achievement, as it involved coordination among 13 European lenders and an Asian export credit agency. The innovative use of legal frameworks in multiple jurisdictions, some of which were unprecedented, allowed Prosafe to effectively resize its balance sheet and convert debt into equity for key financial creditors, thereby stabilizing its financial position and securing its operational future.