LLC Charging-Order Protection by Jurisdiction
What a judgment creditor can actually reach when the debtor's asset is a membership interest — charging-order exclusivity, single-member coverage, and foreclosure availability, recorded from each jurisdiction's own entity statute.
Short answer
When a judgment creditor comes after a membership interest rather than an asset, what the creditor can reach depends on whether the jurisdiction makes a charging order the exclusive remedy, whether that exclusivity extends to single-member entities, and whether foreclosure on the interest remains available. This matrix records those three terms, plus the governing statute, for each jurisdiction from its own official source.
The matrix
| State | Statute Name | Charging Order Exclusive | Single Member Entity Covered | Foreclosure Available | Tier |
|---|---|---|---|---|---|
| Cook Islandschecked 2026-09-13 | Limited Liability Companies Act 2008 (Cook Islands), No. 7 of 2008 | Y | Y | N | 4 |
| St. Kitts & Nevis — Nevischecked 2026-09-13 | Nevis Limited Liability Company Ordinance, 2017 (No. 2 of 2017), CAP. 7.04(N) (revised/consolidated edition). Replaces the prior fork's wrong-instrument use of the Federation-level Companies Act CAP. 21.03, which has no charging-order concept at all and was researched under the pre-correction divergence map that excluded Nevis-specific instruments from this matrix. | Y -- s.60(5): 'Notwithstanding any other law, the remedies provided by subsection (1) [a court-ordered charge on the member's interest] shall be the SOLE remedies available to any creditor of a member's interest, whether the limited liability company has a single member or multiple members.' s.60(6) additionally bars foreclosure, seizure, levy, attachment, or a court order for accounting as alternatives. | Y -- s.60(5) EXPRESSLY states the exclusive-remedy rule applies 'whether the limited liability company has a single member or multiple members' (ruling (d)'s 'Y' condition: expressly names single-/sole-member entities). | N -- s.60(6)(a): foreclosure is explicitly listed among remedies NOT available to the judgment creditor ('No other remedy of any type, legal or equitable, including... (a) foreclosure... is available'). | 4 |
| St. Kitts & Nevis — Federationchecked 2026-09-13 | Companies Act, CAP. 21.03 (Saint Christopher and Nevis, federation level) — no LLC-equivalent vehicle exists at federation level (distinct from the Nevis Island Administration's own Limited Liability Company Ordinance CAP. 7.04(N), which governs the skn--nevis row separately). Judgment-creditor charging orders over a member's shares are a general civil-enforcement matter under Eastern Caribbean Supreme Court Civil Procedure Rules (Revised Edition 2023), Part 48 — not addressed in the Companies Act itself. | N | silent | Y | 4 |
| Liechtensteinchecked 2026-09-13 | Personen- und Gesellschaftsrecht (PGR), LGBl. 1926 Nr. 4 (as amended) Art. 405 c) 'Bei Zwangsvollstreckung oder Konkurs' (GmbH share transfer on compulsory execution/bankruptcy); general mechanism under Gesetz über das Exekutions- und Rechtssicherungsverfahren (Exekutionsordnung, EO), LGBl. 1972 Nr. 32, Art. 241-250 'Exekution auf andere Vermögensrechte'. | N | silent — the remedy concept (a charging-order-style exclusivity protection limiting the creditor to distributions) does not exist at all in this system; PGR Art. 405's co-member pre-emption mechanism applies uniformly with no member-count distinction, and it protects OTHER MEMBERS' choice of new co-member, not the debtor-member from the creditor. | Y | 1 |
| Cypruschecked 2026-09-13 | Unverified (no primary source yet) | Unverified (no primary source yet) | Unverified (no primary source yet) | Unverified (no primary source yet) | Unverified (no primary source yet) |
| Jerseychecked 2026-09-13 | Limited Liability Companies (Jersey) Law 2018 (L.32/2018) — contains no provision addressing charging orders, execution, or foreclosure against a member's LLC interest. | N | silent | Not yet researched | Not yet researched |
| Switzerlandchecked 2026-09-13 | Unverified (no primary source yet) | Unverified (no primary source yet) | silent -- the remedy concept (charging order) does not exist at all in this system (ruling (d) names 'Switzerland' as exactly this case). Confirmed by targeted search of the Debt Enforcement and Bankruptcy Act (SchKG) for 'GmbH'/'limited liability company'/quota/Anteil: no LLC-membership-interest-specific seizure provision exists anywhere in the Act; a member's interest would be attached under the ordinary, generic distraint/realization-of-rights framework applicable to any property or claim, with no member-count distinction. | Unverified (no primary source yet) | 1 |
| Monacochecked 2026-09-13 | Unverified (no primary source yet) | Not yet researched | Not yet researched | Not yet researched | Not yet researched |
| Italychecked 2026-09-13 | Unverified (no primary source yet) | Unverified (no primary source yet) | Unverified (no primary source yet) | Unverified (no primary source yet) | Unverified (no primary source yet) |
| Greecechecked 2026-09-13 | Unverified (no primary source yet) | Unverified (no primary source yet) | Unverified (no primary source yet) | Unverified (no primary source yet) | Unverified (no primary source yet) |
| Uruguaychecked 2026-09-13 | Ley N° 16.060 (Ley de Sociedades Comerciales, 1989-11-01), Art. 78 ('Embargo de participaciones sociales') and Art. 232 ('Cesión de cuotas a terceros', incisos 4-5, cross-referenced by Art. 78's final sentence for SRL cuotas specifically). | N | silent — the remedy concept (Art. 78's charging-order-style exclusive/distributions-only protection) does not exist at all for SRL, which is expressly carved out of Art. 78 regardless of member count; forced execution subject to the Art. 232(4)-(5) pre-emption right applies uniformly. | Y | 1 |
| Panamachecked 2026-09-13 | Ley No. 4 de 9 de enero de 2009 ('Que regula las Sociedades de Responsabilidad Limitada') -- Panama's actual LLC-equivalent entity law (SRL), superseding the prior fork's wrong-statute use of Ley 32 de 1927 (general corporation law, Sociedad Anonima -- a different entity type entirely). | N -- no charging-order concept exists. Read in full (575 lines/48 articles): Art. 18 permits a member to voluntarily PLEDGE (prenda) their cuota social to a lender, a contractual security arrangement, not a judgment creditor's remedy against an unwilling member. Arts. 45-48 (dissolution/bankruptcy) address the COMPANY's own insolvency and composition with ITS creditors, not a judgment creditor of an individual member reaching that member's interest. No provision addresses a judgment creditor's remedy against a member's cuota at all. | silent -- the remedy concept (charging order) does not exist at all in this system (ruling (d) names 'Panama SRL' as exactly this case). Independently confirmed via Art. 4: an SRL requires a MINIMUM OF TWO members at formation ('el numero de socios, no menor de dos'), so single-member SRL formation is not even contemplated, reinforcing why no single-member carve-out language exists. | Not yet researched | Not yet researched |
| United Arab Emirates — Mainlandchecked 2026-09-13 | Federal Decree-Law No. 32 of 2021 on Commercial Companies (Commercial Companies Law / CCL), as amended by Federal Decree-Law No. 20 of 2025 (amendments effective 2026-01-01) — Article (20) [general] and Articles (79)-(82) [LLC chapter] | N | silent -- CORRECTED from 'Y' per ruling (d): the prior 'Y' was a structural inference (OPC governed by the same chapter, no textual carve-out), not an EXPRESS statement naming single-member entities, which ruling (d) requires for 'Y'. The actual finding -- 'the exclusivity rule applies uniformly with no member-count language' -- is precisely ruling (d)'s 'silent' definition. | Y | 1 |
| United Arab Emirates — DIFCchecked 2026-09-13 | DIFC Courts Rules (RDC), Part 46 — Charging Orders, Stop Orders and Stop Notices, rule 46.24 (enforcement of charging order by sale). The DIFC Companies Law (DIFC Law No. 5 of 2018, as amended) itself contains no separate member-protective charging-order-exclusivity provision; enforcement against a shareholder's securities in a DIFC company proceeds under this generic DIFC procedural rule. | N | silent | Y | 4 |
| United Arab Emirates — ADGMchecked 2026-09-13 | ADGM Court Procedure Rules 2016 (30 Nov 2023 consolidation), Part 32 (Charging Orders, Stop Orders and Stop Notices) | N | silent | Y | 4 |
| United Arab Emirates — RAK ICCchecked 2026-09-13 | RAK ICC Business Companies Regulations 2018 | Not yet researched | Not yet researched | Not yet researched | Not yet researched |
| Singaporechecked 2026-09-13 | Rules of Court 2021 (S 914/2021), O.22 rr.6-7 -- general civil enforcement of judgments; shares handled via 'seizure and sale', not a Companies Act provision | N | silent | Y | 4 |
| Hong Kongchecked 2026-09-13 | High Court Ordinance (Cap. 4) ss.20-20B -- general civil charging-order provisions covering land/securities/funds-in-court, not Companies-Ordinance-specific | N | silent | Y | 4 |
| Estoniachecked 2026-09-13 | Code of Enforcement Procedure (Taitemenetluse seadustik) Sec. 125 'Levy on a share in a private limited company' | N | silent | Y | 4 |
| Vanuatuchecked 2026-09-13 | International Companies Act [CAP. 222] (Laws of the Republic of Vanuatu, Consolidated Edition 2006) — Vanuatu's offshore/international company vehicle; no LLC-specific act exists (the domestic Companies Act No. 25 of 2012 governs local companies separately and is not the operative asset-protection vehicle). Judgment-creditor charging orders over shares: Vanuatu Civil Procedure Rules No. 49 of 2002, Part 14 Division 6 (ss.14.33-14.36). | N | silent | Y | 4 |
| United Kingdomchecked 2026-09-13 | Charging Orders Act 1979 (c.53) + Civil Procedure Rules Part 73 | N | silent | Y | 4 |
| Wyomingchecked 2026-09-13 | Wyoming Limited Liability Company Act | Y | Y | N | 1 |
| Nevadachecked 2026-09-13 | Nevada Revised Statutes Chapter 86 (Limited-Liability Companies) | Y | Y | N | 1 |
| South Dakotachecked 2026-09-13 | Unverified (no primary source yet) | Unverified (no primary source yet) | Unverified (no primary source yet) | Unverified (no primary source yet) | Unverified (no primary source yet) |
| Delawarechecked 2026-09-13 | 6 Del. C. Sec. 18-703 | Y | Y | N | 1 |
| Floridachecked 2026-09-13 | Fla. Stat. Sec. 605.0503 | Y | N | Y | 3 |
| Puerto Ricochecked 2026-09-13 | Ley General de Corporaciones de 2009 (Ley Núm. 164 de 16 de diciembre de 2009, según enmendada), Título 14, Subtítulo 5, Capítulo 239 (Compañías de Responsabilidad Limitada), Artículo 19.44 (codified at 14 L.P.R.A. § 3994) | Y | silent | Y | 3 |
Hover column headers to see field definitions. Hover cell text to see source notes. Typed unknowns (e.g., “Portal not observable”) are methodological limits, not data gaps.
Research scope
Rows are the jurisdictions on the Private Pierce international roster, plus six US jurisdictions — Wyoming, Nevada, South Dakota, Delaware, Florida, and Puerto Rico. The US rows are here because they legislate on this same axis and are the jurisdictions readers most often hold up against an offshore option; putting them in the same table on the same fields lets the statutory terms be read against each other instead of described in two separate vocabularies. Where a jurisdiction runs more than one regime, the divergent regimes appear as their own rows directly beneath the parent. Cells that read as not established or unknown are typed unknowns — the research pass did not confirm that field against an official source, the reason is on hover, and they will be backfilled through this same data file rather than by rewriting this page.
How to read this matrix
Each row is a jurisdiction. statute_name identifies the entity statute or, in civil-law jurisdictions with no charging-order concept, the general execution law that governs instead. charging_order_exclusive records whether the charging order is the creditor's only remedy against the interest; single_member_entity_covered records whether that rule extends to an entity with one member, which is where jurisdictions most often diverge; foreclosure_available records whether the creditor may instead foreclose on the interest itself. tier records how the jurisdiction's regime is characterized on this axis. Sub-rows carry the regime-specific value for a parent jurisdiction that runs more than one entity regime.
What this page does not claim
- It does not tell you what a creditor will recover. Remedy availability on paper is not a prediction of a collection outcome, which turns on facts this matrix does not have.
- It does not resolve conflict of laws. Which jurisdiction's entity law a court applies to a membership interest is a separate, fact-specific question.
- It does not rank or recommend. The tier field characterizes a statute, not a fit for any reader, and foreign law described here may have changed since it was read.
Sources
Each row links to one primary official domain for that jurisdiction, chosen as its lead source. Every published cell carries its own pinpoint citation, source URL, and the first segment of the snapshot hash of the document it was read from, visible on hover; the snapshots themselves are retained on file. Where a jurisdiction publishes a consolidated text, the consolidation date it was read at is recorded with the underlying matrix rather than restated here. The full source taxonomy lives at /about/source-registry/, and the research method at /about/methodology/.
Not legal advice
Private Pierce is not a law firm and does not provide legal advice.
Nothing on this page is legal, tax, or immigration advice, and it is not a recommendation to use any jurisdiction; foreign law is described from official sources as published and may have changed — consult counsel licensed in the relevant jurisdiction.
Frequently asked questions
What is a charging order?
It is a court order directing that distributions otherwise payable to a debtor member be paid to the creditor instead. The question this matrix records is how far each jurisdiction's statute goes: whether the charging order is the creditor's only remedy, or whether the creditor may also foreclose on the interest itself.
Why does single-member coverage get its own column?
Several jurisdictions write charging-order exclusivity in terms that courts have read as protecting multi-member entities while leaving single-member entities outside the rule. The matrix records what each statute says about single-member entities separately from the general exclusivity rule, because the two frequently diverge.
Why are some cells marked unknown rather than filled in?
A cell publishes a value only where this research pass confirmed it against that jurisdiction's own official source. Where the citation chain traced only to secondary or academic material, or where nothing citable was located, the cell is held as an unknown with its reason on hover rather than published as a fact. Those are backfill targets, not claims.
Go deeper with source-backed research
Explore methodology, datasets, and related matrices cited on this page.