For a foreign law firm, instructing French counsel should not mean losing control of the client relationship or fragmenting the litigation strategy. The most effective model is often a defined French-law workstream integrated into the existing international team.
French counsel can have a limited or comprehensive mandate
Some matters require only a short French-law opinion: whether French courts have jurisdiction, whether an ownership rule applies, whether evidence can be obtained in France, or how a foreign judgment can be enforced. Other matters require full French proceedings.
The mandate should be defined by function rather than geography alone. French counsel may handle court procedure, evidence, local authorities, French counterparties and substantive French law while foreign lead counsel retains responsibility for the overall multi-jurisdictional case.
The client relationship can remain with the referring firm
Fournol & Associés is accustomed to working alongside foreign lawyers and understands the importance of referral relationships. The Firm can communicate through lead counsel, join client calls where useful and provide analysis in English designed to fit the broader litigation strategy.
Where direct client instruction is required for French proceedings or professional obligations, the structure can be agreed transparently with referring counsel. The objective is collaboration rather than displacement.
A specialist art-market practice reduces translation between law and market
International art disputes often require counsel to understand not only legal concepts but auction practice, authenticity terminology, provenance records, expert relationships, consignments, market confidentiality and reputational risk.
The Fournol & Associés Art Market practice is dedicated to these issues and represents auction houses, galleries, dealers, experts, collectors and institutions in French and cross-border matters. This allows foreign counsel to use one French team for both procedural litigation issues and the underlying art-market context.
French counsel can connect existing specialist workstreams
An international dispute may begin as a contract claim and develop into an ownership, customs or criminal issue. The existing English publications on provenance and ownership, French customs documentation and customs detention illustrate how quickly those subjects can intersect.
Likewise, an acquisition dispute can involve KYC questions at the transaction stage. Our article Why Is a French Auction House Asking for My ID? provides the French AML/CFT context for foreign buyers.
Paris and Brussels can be coordinated through one relationship
The Firm’s core litigation practice is French, with Paris as its principal base, but it also assists art-market clients in Brussels. For matters centered on Brussels that can be handled directly, Fournol & Associés may act itself; in Belgian contentious proceedings, the Firm can work with a local Belgian lawyer where appropriate or required.
For a London, New York, Geneva or other foreign firm, this can reduce coordination costs where the same art-market matter has significant French and Belgian dimensions.
What foreign counsel should send at the outset
An efficient initial instruction usually includes a short chronology, key parties and jurisdictions, the contract and terms of sale, the principal correspondence, current procedural deadlines and the specific French question. Where title or authenticity is involved, photographs, provenance, expert documents and the current location of the work are also useful.
This allows the French workstream to begin with conflict checks and issue identification rather than a broad re-review of the entire international file.
About the author
Alexis Fournol, Attorney at the Paris Bar and Partner at Fournol & Associés, advises and represents French and international art-market professionals, collectors, experts and institutions in disputes involving art, cultural property, authenticity, ownership, customs and related criminal or regulatory issues.
How Fournol & Associés can assist
Fournol & Associés regularly accepts referrals and co-counsel mandates from foreign law firms. The Firm can provide French-law opinions, conduct pre-litigation correspondence, obtain evidence, manage expertise, bring or defend French proceedings, handle urgent applications and support recognition or enforcement. The scope can remain tightly defined around the French issues.
Fournol & Associés regularly acts as French counsel within international legal teams. Foreign law firms may instruct the Firm for a defined French-law issue, for proceedings in France, or for the French component of a wider multi-jurisdictional dispute. The Firm works in English and coordinates closely with lead counsel, experts and other advisers.
The Firm also assists clients in Brussels, particularly in art-market matters. Depending on the nature of the matter, we may act directly or, in contentious proceedings, work alongside Belgian counsel where appropriate or required.
Related reading
- Firm — the Firm’s cross-disciplinary and international positioning
- Art Market — dedicated art-market practice
- Insights — English-language French art-law publications
- Contact — instructions and conflict-check information
Contact Fournol & Associés for a French-law or France/Brussels art-market matter.
This publication provides general information on French law and does not constitute legal advice. The applicable rules depend on the facts, relevant agreements, jurisdictions involved and procedural posture of each matter.
Frequently Asked Questions
Will Fournol & Associés take over the client from the referring foreign firm?
The Firm is accustomed to co-counsel and referral relationships and can structure its role around the French workstream while the referring firm remains lead counsel.
Can you provide a French-law opinion without commencing proceedings?
Yes. The mandate can be limited to a French-law, jurisdiction, evidence, regulatory or enforcement issue.
Can you work directly in English with the international legal team?
Yes. The Firm works in English and can provide advice, strategic notes and coordination directly to foreign counsel and international clients.
Can the same relationship cover Brussels?
The Firm also assists art-market clients in Brussels. Depending on the matter, it may act directly or coordinate with Belgian counsel in contentious proceedings.
