Alert 04.08.26
Asset-Based Lending in England and the U.S.: A Comparative Insight for Cross-Border Transactions
With a strong history in the U.S., asset-based lending is becoming an attractive debt finance product offering in England.
Max Griffin advises on a full-spectrum of banking and finance matters, both syndicated and bilateral, including corporate lending, real estate finance, fund finance and asset finance.
Max regularly acts for financial institutions, borrowers and leasing companies on cross-border financings across the United States, Europe and Asia. Prior to joining the firm, Max worked in the banking department of two multinational law firms. She has further experience in trade and commodity finance and sovereign lending. Max has experience in negotiating a wide variety of loan documentation, along with conducting due diligence.
Representative Experience
- Advised Branded in relation to financing aspects, in relation to its acquisition of Heydey, leading to the formation of Essor.
- Advised Harbor Group International in relation to the refinancing of The Relay Building, a 22-story mixed-use tower originally acquired in 2018 for £90.75 million.
- Advised joint lead managers, including Abu Dhabi Commercial Bank, on Saudi-based aircraft leasing company AviLease’s $2.5 billion aviation financing. The matter will be recognized as Transport Finance Deal of the Year at the 2025 Global Banking & Markets Saudi Arabia Awards.
View More
- Advised energy commodity company in relation to a $40 million project financing of four oil wells located in Texas.
- Advised a floating offshore wind developer in relation to the financing and development of seabed leases awarded under the Innovation and Target Oil & Leading Round organized by the Crown Estate Scotland.
- Advised Diversified Holdings Limited in relation to real estate financing of a portfolio of real estate companies located in the United Kingdom.
- Advised Elliott Management Corporation as a non-bank lender in a $3 million payment in kind equity notes investment in relation to a LMA style New York law financing.
- Advised Branded (now Essor) in relation to several amendments and amendments and restatements to the English law facilities agreement, including in the context of certain corporate restructurings.
- Advised JUUL in relation to the English law aspects in relation to their New York law governed financing agreements.
- Advised Checkout Technology Limited in respect of corporate treasury for the Checkout group.
- Advised a leased and tenanted pub company in connection with a refinancing of its facilities by way of a £30 million revolving credit facility secured on its estate of over 350 pubs across England, Wales and Scotland.
- Advised Northern Trust Group, the property investment, development and land regeneration company, in relation to a £270 million facility arranged by M&G Investments. The facility was secured against Northern Trust’s portfolio of industrial, trade and office parks, comprising over 4,500 individual units in total and its c. 1,500-acre land bank.
- Advised JP Lease Products & Services in closing a Japanese operating lease with call option financing of three Airbus A320 aircraft, with ICBC Financial Leasing as intermediate lessee. This was the first JOLCO of its kind in the U.S. market utilizing the U.S. owner-trust structure.
Professional Highlights
- Recognised as a Rising Star (UK) by Expert Guides: Banking and Finance (2022)
- Trustee, Shpresa Programme (2018–2024)
- Recognised on the Pro Bono Recognition List (2024–2025)
View More
- Member of the International Aerospace Womens Association
- External Publications
- “Rays of Hope: There is cautious optimism for real estate finance in a shifting marketing,” Institutional Real Estate Europe, Authors: Victoria Judd, Max Griffin, July 1, 2025
- “Private credit and banks redraw the lending map,” Business Reporter, Authors: Victoria Judd, Max Griffin, April 7, 2025
- “From Principles to Practice: Creating a Strong Future for Green Finance”, edie, Authors: Victoria Judd, Max Griffin, April 7, 2025
- “Unlocking the potential of the U.K. finance market for European commercial real estate | News,” Institutional Real Estate, Inc. (irei.com), Authors: Max Griffin, March 25, 2024
- “The Tortoise and the Hare of Sustainable Investing,” Author: Max Griffin, Sept. 15, 2023
- Firm Publications
- Loan Market Association Publishes Green Loan Terms, Smoothing Path for Green Finance in 2025, Authors: Max Griffin, Victoria Judd, Joel Simon, Jan. 17, 2025
Education
-
Legal Practice Course, BPP Law School, 2016
Graduate Diploma, The University of Law, 2015
M.A., University of Edinburgh, 2014
Admissions
-
England and Wales
Languages
-
Japanese