Cross-border

Your US counsel cannot advise on German law. We can send it to someone who can.

A US software company selling internationally signs contracts governed by law its own lawyer is not admitted to practise. Most firms handle this by referring you out. We handle it by having already built the network.

This is the part of the offer that is genuinely hard to copy, and it is the reason Engross exists at all rather than being one more US contract shop.

Icon Partners has worked across more than 40 jurisdictions since 2012 — corporate structuring, licensing, tax and commercial work, with locally qualified lawyers in each market. Engross puts that network behind a US contract desk.

SaaS agreement · EU enterprise customer§ 16 Governing law

16.1This Agreement shall be governed by the laws of the State of New Yorkthe Federal Republic of Germany, excluding its conflict-of-law rules. The courts of Berlin shall have exclusive jurisdiction.

Cross-border · local counsel engagedDE

The moment it stops being a US contract

One clause, and half the document now means something else.

Governing law is the clause nobody fights about — until a European enterprise customer insists on their own. At that point the liability cap, the warranty disclaimers and the termination mechanics are all read under a different legal system, and a US-only lawyer is now guessing. We do not guess. We hand it to someone qualified there, and you never see the hand-off.

The rule we work by

Local law, local lawyer. Always.

US law

Handled by [Firm Name, PLLC], attorneys admitted in New York. Advice on the law of a US state comes only from counsel admitted there. Where a matter touches a state outside our admission, we bring in admitted local counsel rather than stretching.

Everything else

Handled by locally qualified lawyers in the relevant jurisdiction, coordinated through Icon Partners. You get one point of contact and one invoice instead of assembling and managing three separate firms yourself.

Why we are strict about this

When local-law advice is required, we use locally qualified counsel. Always. A single office claiming to cover forty countries is the claim worth examining — not because it is always wrong, but because the advice is only as good as the qualification behind it.

Where it comes up

The situations that trigger it.

EU customer, EU lawEnterprise buyers who will not accept New York governing law
GDPR and SCCsTransfer mechanisms, DPAs, local supervisory expectations
UK after BrexitSeparate regime, separate paper, routinely missed
Reseller and distributionLocal agency and termination protections that override your contract
Employment-adjacent contractorsClassification rules that differ sharply by country
Local entity setupWhen the contract requires a local presence to sign
Consumer-facing termsMandatory local rules your US template ignores
Regulated counterpartiesFinancial, health and public-sector buyers with their own regimes

Next step

Bring the contract that is stuck.

Usually it is one clause and one jurisdiction. Twenty minutes is generally enough to tell you whether it is a real problem or a drafting one.

Book a contract call