Project finance — Checklist for formalities relating to securities

Introductory note:
In major international projects, it is highly likely that more than one jurisdiction will be relevant to the security package given to the lenders.
The term “onshore security” refers to any security which is governed by the laws of the jurisdiction in which the project is located.
The term “offshore security” refers to any security which is governed by the laws of any other jurisdiction.
Security must satisfy any relevant formalities in each relevant jurisdiction. This checklist provides a list for key formalities that legal practitioners should take into consideration when drafting or reviewing onshore and offshore securities.