An increasingly common feature of legislation on financial services, consumer protection, unfair competition and the like, is provision which allows an agency to bring proceedings against a wrongdoer—a person who carried on unauthorized investment business, obtained funds obtained by fraud, uses unfair terms in consumer contracts, that sort of thing—in circumstances where the victims are many but inhibited from claiming in their own right. An English example is to be found in the Financial Services and Markets Act 2000 (“FiSMA”).1 Section 382 allows for “restitution orders” to be made for contravention of requirements imposed by the Act, and s 383 allows the same for cases of market abuse. The Act empowers the court, on the application of the Financial Services Authority or the Secretary of State, to make an order against someone who has committed the relevant wrong and who has made a profit or caused a loss by doing so.2 Such actions serve a clear public need. Individuals may be disinclined to throw good money after bad, and be put off by the cost or the uncertainty of recovery, while others may be deterred by the risk of publicity in raising a complaint in their own names. Yet they have suffered loss. And, from the public perspective, there has to be an effective sanction to deter would-be wrongdoers from ignoring a regulatory scheme established by the law, or from otherwise engaging in unfair trade practices. Such schemes often lie at the border of civil, regulatory and criminal law; and questions of private international law inevitably arise in their wake. If one thinks about it from an English point of view, one may ask (1) what if the proceedings are taken under English legislation but the defendant is not domiciled in England? (2) what if the proceedings are brought in England by a foreign entity on the basis of a foreign scheme? (3) what if a judgment under a foreign scheme is obtained overseas, and an attempt made to enforce it in England against the local assets of a defendant?