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JURISDICTIONS

53 jurisdictions. Every conflict automatically resolved.

No other system in the world resolves legal conflicts between 53 jurisdictions deterministically, in under 200 milliseconds, with court-admissible proof of the applied doctrine.

53
Jurisdictions covered
12
Conflict rules
6
Resolution doctrines
<200ms
Conflict resolution
LIVE CONFLICT MATRIX

Real jurisdiction conflicts. Deterministic resolutions.

Click any conflict to see the full analysis, the applied doctrine and the resolution.

Illustrative excerpt from the full 53Ă—53 register
Illustrative Kollisionsmatrix von 10 Jurisdiktionen mit hervorgehobenen bekannten Rechtskonflikten DE EU US UK CH FR NL SG AE CN DE EU US UK CH FR NL SG AE CN
Known conflict · doctrine on file
No known conflict
Same jurisdiction
GDPR Art. 17 (Right to Erasure) vs. GwG §8 (10-Year Retention Obligation)
The most common conflict in German financial institutions
GDPRGwGDE
HIGH
GDPR ART. 17 — EU
Right to be forgotten
Data subject has the right to request deletion of their personal data. Processing without legal basis is prohibited. Violation: up to 4% of global annual turnover.
VS
GwG §8 — DE
Retention obligation AML data
All AML-relevant records must be retained for 10 years. Deletion is criminal. BaFin fine up to €5M or 10% of annual turnover.
RESOLUTION — IMMO.QUICK CORE
Doctrine: Lex Specialis Derogat Legi Generali
GwG §8 as the more specific law takes precedence over GDPR Art. 17 for AML-relevant data. Solution: AML data retained for 10 years (GwG). All other personal data deleted per GDPR timelines. The separation is cryptographically enforced — not through manual decision.
✓ Automatically resolved · <9ms · WORM-documented
GDPR Art. 44 (Data Transfer) vs. US CLOUD Act (Mandatory Access for US Authorities)
The most well-known and dangerous legal conflict of the digital world
GDPRCLOUD ActEU/US
CRITICAL
GDPR ART. 44 — EU
Data transfer to third countries
Transfer of personal data to US authorities without adequacy decision violates GDPR. EDPB: CLOUD Act compliance can constitute GDPR violation.
VS
US CLOUD ACT — US
Compelled data disclosure
US authorities can force American cloud providers to hand over European customer data — even if it is located in the EU. Violation: criminal consequences for the company.
RESOLUTION — IMMO.QUICK CORE
Doctrine: EDPB Schrems II Framework + Physical TEE Sovereignty
All data resides in EU-TEE Frankfurt (AWS Nitro Enclave, PCR0-attested). No US cloud provider has physical access. CLOUD Act does not apply to data physically residing in EU hardware enclaves — not even for the enclave operator. CLOUD Act immunity certificate issued, QES-signed, RFC-3161 timestamp.
✓ CLOUD Act Immune · Physically and cryptographically proven
Swiss Banking Secrecy (Art. 47 BankG) vs. FATCA (US Tax Compliance)
Daily reality for every Swiss bank with US clients
CH BankGFATCACH/US
HIGH
ART. 47 BANKG — CH
Swiss Banking Secrecy
Bankers and their employees are obligated to maintain confidentiality about client information. Violation is criminal (imprisonment up to 3 years or fine). Applies also to foreign authorities.
VS
FATCA — US
Foreign Account Tax Compliance Act
Foreign financial institutions must report information about US persons to the IRS. Non-compliance: 30% withholding tax on all US payments. Practically no foreign financial institution can avoid FATCA.
RESOLUTION — IMMO.QUICK CORE
Doctrine: Treaty-Based Compliance via Staatliches Amtshilfeabkommen CH-USA
FATCA compliance is processed through the Swiss-US mutual assistance agreement — not through direct data access by US authorities. The system generates a FATCA-compliant report containing the necessary tax data without directly breaking banking secrecy. The legal basis (mutual assistance agreement) is sealed as a court-admissible document.
âś“ FATCA-compliant without banking secrecy violation
EU GDPR Art. 17 vs. US FISA Section 702 (Intelligence Access)
The most serious privacy problem for EU companies using US cloud
GDPRFISA 702EU/US
CRITICAL
GDPR + ECHR ART. 8 — EU
Data protection as fundamental right
GDPR prohibits the transfer of personal data to foreign authorities without legal basis. ECHR Art. 8 protects the right to privacy as a human right.
VS
FISA SECTION 702 — US
Mass surveillance by NSA/FBI/CIA
US intelligence agencies can require US companies to surveil communications and data of non-US persons — with a gag order requiring the company not to disclose this.
RESOLUTION — IMMO.QUICK CORE
Doctrine: Physical Sovereignty via TEE + Warrant Canary Protocol
Data in EU-TEE cannot physically be transmitted to US intelligence agencies — the enclave operator itself has no access to the plaintext data. Additionally: daily signed Warrant Canary — confirming no FISA request received. When the canary stops: users know immediately. FISA Terminal Refusal Protocol documents the legally grounded refusal.
✓ Physically FISA-immune · Warrant Canary active
MiFID II Transparency Obligations vs. Swiss Banking Secrecy (FIDLEG Exemption)
Critical for cross-border derivatives and securities transactions
MiFID IIFIDLEGEU/CH
MEDIUM
MiFID II — EU
Securities trading transparency obligations
Pre- and post-trade transparency for all securities. Best execution documentation. Transaction reporting to regulators. Applies to all financial institutions operating in the EU.
VS
FIDLEG ART. 3 — CH
Professional clients exemption
For professional clients (institutional investors, banks, insurers) significantly reduced transparency obligations apply under the Swiss Financial Services Act. Swiss banking secrecy further restricts reporting.
RESOLUTION — IMMO.QUICK CORE
Doctrine: Jurisdictional Scoping + Professional Client Classification
The transaction is jurisdictionally split: EU part (derivatives on London exchange) subject to full MiFID II. CH part (Zurich bank accounts) falls under FIDLEG exemption for professional clients. The system automatically classifies, documents the legal basis for each part separately, and seals both as court-admissible artifacts.
✓ Dual compliance · EU + CH simultaneously
EU GDPR Data Localization vs. MAS Singapore Cross-Border Data Requirements
Relevant for all APAC operations of European financial institutions
GDPRMASEU/SG
MEDIUM
GDPR ART. 44-49 — EU
Third country transfer restrictions
Transfer of personal data to Singapore only with adequate level of protection. SCCs (Standard Contractual Clauses) or BCRs required. Transfer Impact Assessment mandatory.
VS
MAS NOTICE — SG
Outsourcing and cross-border requirements
MAS requires financial institutions to localize customer data in Singapore or ensure MAS access to all data, even if stored abroad. Regulatory auditability must be guaranteed.
RESOLUTION — IMMO.QUICK CORE
Doctrine: ZKP-Based Regulatory Access + Data Minimization
Customer data remains in the EU (GDPR requirement met). MAS receives via Zero-Knowledge Proof a compliance attestation without access to PII data. Transfer Impact Assessment automatically generated and WORM-sealed. MAS regulator access for specific audits: JIT access with time limitation.
✓ GDPR + MAS simultaneously · ZKP-based
OFAC SDN Obligations vs. EU Blocking Statute (Protection Against US Extraterritoriality)
Iran, Cuba, Venezuela sanctions vs. EU corporate obligations
OFACEU BlockingUS/EU
CRITICAL
OFAC SDN — US
Extraterritorial US sanctions
OFAC requires all companies worldwide — even without US nexus — to comply with US sanctions (Iran, Cuba, Venezuela). Violation: up to $1M fine per transaction, criminal prosecution, exclusion from USD system.
VS
EU BLOCKING STATUTE — EU
Protection against US extraterritoriality
EU Regulation 2018/1100 prohibits EU companies from complying with certain US secondary sanctions. Companies that comply with OFAC secondary sanctions can be penalized by EU authorities.
RESOLUTION — IMMO.QUICK CORE
Doctrine: Primary vs. Secondary Sanctions Scoping + EU Blocking Compliance
The system automatically distinguishes between US primary sanctions (direct US nexus — OFAC compliance mandatory) and US secondary sanctions (no direct US nexus — EU Blocking Statute applies). For every transaction: automatic classification, documented legal justification, WORM-sealed artifact. EU companies are legally protected in both regimes simultaneously.
✓ OFAC + EU Blocking · Dual-regime compliance
THE 6 RESOLUTION DOCTRINES
DOCTRINE 1
Lex Specialis
More specific law supersedes general law. Applied for: GwG vs. GDPR, local tax laws vs. EU data protection.
DOCTRINE 2
Lex Posterior
More recent law supersedes older law. Applied for: GDPR (2018) vs. older privacy laws, new FATF standards vs. national AML rules.
DOCTRINE 3
Physical Sovereignty
Physical location of data determines applicable law. Applied for: CLOUD Act, FISA, US jurisdiction vs. EU data protection.
DOCTRINE 4
Treaty Primacy
State treaty supersedes unilateral national law. Applied for: FATCA vs. banking secrecy (mutual assistance treaty), MLAT agreements.
DOCTRINE 5
ZKP Separation
Cryptographic separation of compliance proof and data content. Applied for: GDPR + FATF simultaneously, AML + Privacy.
DOCTRINE 6
Jurisdictional Scoping
Transaction is jurisdictionally split — each part governed by its own law. Applied for: MiFID II + FIDLEG, EMIR + local derivatives laws.

Your jurisdiction conflict not listed?

immo.quick Core knows 12 conflict rules and 6 resolution doctrines for all 53 jurisdictions. Contact us for a specific conflict analysis.

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