For high-net-worth (HNW) and ultra-high-net-worth (UHNW) borrowers, wealth rarely sits in one country. Property portfolios stretch from London to Lisbon, investments flow through European and offshore structures, and family offices manage assets across multiple time zones. But while wealth may be global, borrowing against it is far from straightforward.
In 2025, cross-border lending remains one of the most complex — yet most rewarding — aspects of private finance. Traditional banks are cautious, regulators are vigilant, and currency volatility is reshaping the economics of international lending. Yet for borrowers who understand how to structure deals properly, the opportunities are immense.
Whether funding a villa in the south of France, refinancing a portfolio held through a Jersey trust, or releasing equity from London assets to acquire property in Spain or Dubai, cross-border finance demands precision, preparation, and partnership with the right lenders.
Why Cross-Border Finance Has Become a Strategic Tool
In the past, international borrowing was largely reactive — a necessity when a borrower happened to own assets abroad. In 2025, it has become an intentional strategy. HNW borrowers now seek to match the currency and jurisdiction of their assets and liabilities, hedge exposure to shifting interest rates, and diversify lender relationships beyond a single market.
For example, a UK resident earning in sterling but holding assets in France may prefer to borrow in euros, avoiding currency conversion costs and aligning the liability with the property’s cash flow or potential sale proceeds. Others use international lending to unlock liquidity in one market while reinvesting in another, capitalising on exchange rate differentials or regional value gaps.
The key is control. Cross-border lending allows borrowers to balance global wealth in motion — ensuring liquidity is available wherever opportunity arises.
The Challenges of Cross-Border Borrowing
Despite its appeal, arranging finance across jurisdictions is not simple. Each country has its own legal, regulatory, and tax environment. Lenders face the challenge of underwriting assets held in unfamiliar legal systems, governed by foreign valuation standards and fluctuating currencies.
Borrowers, meanwhile, must navigate cross-border due diligence, lender comfort with offshore ownership, and varying disclosure obligations. Even something as basic as mortgage registration can differ dramatically — a process that takes hours in the UK might take weeks in continental Europe.
In 2025, three challenges dominate:
- Regulatory complexity, as financial institutions comply with differing local and international standards.
- Currency and interest rate volatility, particularly across sterling, euro, and dollar markets.
- Legal enforceability, ensuring that security, guarantees, and charges are valid in every jurisdiction involved.
These are not barriers but considerations. The most successful borrowers approach cross-border lending with professional advisors — ensuring that every legal, tax, and currency element is aligned before a term sheet is even issued.
How Private Credit Is Redefining Cross-Border Lending
Traditional banks have long dominated international lending for corporate clients, but their private banking arms have become increasingly selective. Lending appetite now focuses on low-risk, income-producing assets, often excluding more entrepreneurial or development-based opportunities.
Private credit lenders, family offices, and specialist funds have filled that gap. In 2025, they are the true enablers of cross-border lending. These lenders operate across multiple jurisdictions with dedicated legal teams, structured credit expertise, and flexible underwriting models.
They are less constrained by geographic silos and can structure facilities that bridge currencies or assets in different territories. A borrower might, for instance, use UK property as collateral to raise euros for a project in France, or combine assets in London and Monaco under a single, cross-collateralised facility.
Private credit’s advantage is agility. It can blend currencies, align interest rates to each jurisdiction, and work with offshore entities without hesitation. What matters is collateral strength, borrower credibility, and a clear repayment strategy — not postcode or nationality.
Lender Due Diligence and Risk Mitigation
Lenders engaged in cross-border deals must assess risk through multiple lenses. They look first at asset quality and legal enforceability — ensuring that local law allows security to be registered, and that the borrower (or the borrowing entity) has the authority to grant it.
They then analyse currency exposure, often requiring natural hedging — for example, ensuring a euro-denominated asset secures a euro-denominated loan. In multi-currency deals, lenders may employ derivatives or interest rate swaps to manage exposure.
Tax and compliance play a major role too. Anti-money laundering (AML) and Know Your Customer (KYC) checks extend across borders, with lenders requiring certified identification, proof of source of wealth, and clarity on beneficial ownership structures.
Borrowers who anticipate these demands and prepare comprehensive documentation often find that deals progress quickly — especially when intermediated through firms like Willow Private Finance that can align expectations between international lenders and private clients.
The Importance of Currency Strategy
Currency risk is one of the defining features of cross-border lending in 2025. As interest rate cycles diverge between regions — with the European Central Bank, Bank of England, and Federal Reserve moving at different paces — borrowers must think strategically about which currency to borrow in.
Some choose to match the debt currency with the underlying asset, minimising exposure to exchange rate movements. Others use multi-currency facilities or dynamic hedging to balance liabilities across markets.
Private banks and credit funds now build currency flexibility directly into loan agreements, allowing borrowers to switch exposure mid-term or partially hedge when needed. For global investors, this flexibility has become a vital part of portfolio management.
Legal Structures and Ownership Considerations
Many cross-border borrowers hold property through corporate or offshore vehicles — often for legitimate tax, succession, or privacy reasons. Lenders are familiar with these structures but require absolute transparency.
In practice, this means that loan documentation must clearly identify the beneficial owners, confirm tax compliance, and verify that the borrowing entity has the power to enter into legal agreements under its jurisdiction of incorporation.
Borrowers using trusts, foundations, or multi-layered SPVs should ensure that trust deeds and corporate documents explicitly authorise borrowing and charging of assets. Clear legal opinions from both local and UK counsel are essential to satisfy lenders’ compliance teams.
When executed properly, structured borrowing allows international finance to flow smoothly, with assets in one jurisdiction supporting lending in another — often at higher leverage and with more flexible terms than would otherwise be possible.
The Role of Specialist Advisors
Arranging cross-border finance requires coordination among lawyers, tax specialists, and credit intermediaries who understand the nuances of each jurisdiction involved. A well-structured transaction anticipates differences in enforcement law, stamp duty, and reporting requirements — avoiding delays later.
At Willow Private Finance, our private client team regularly works alongside international law firms, fiduciary providers, and lenders to ensure alignment across all fronts. We focus on lender expectations early — preparing full ownership documentation, compliance packs, and valuation frameworks before a deal reaches credit committee.
This proactive approach transforms what could be a six-month process into a matter of weeks. For UHNW borrowers, the difference between frustration and successful completion often lies in preparation.
How Willow Private Finance Can Help
At Willow Private Finance, we specialise in sourcing and structuring complex, multi-jurisdictional lending for private clients and family offices. Whether you’re refinancing a UK portfolio through a Luxembourg company, acquiring property in France or Spain, or raising cross-border liquidity against global assets, our expertise ensures seamless execution.
We work with a network of private banks, specialist lenders, and credit funds who understand the legal, tax, and operational realities of international lending. Every structure we arrange is discreet, compliant, and tailored to your broader wealth strategy.
Frequently Asked Questions
What makes cross-border lending different from domestic finance?
Cross-border lending involves assets, currencies, and legal systems in more than one country. It requires lenders to manage additional regulatory, tax, and legal considerations while aligning documentation across jurisdictions.
Can I use property in one country to secure finance in another?
Yes. Many private lenders offer cross-collateralised facilities that use property or assets in one jurisdiction as security for borrowing elsewhere — provided the ownership and legal frameworks are transparent.
How do lenders manage currency risk?
Lenders typically match loan currency to asset currency, or they build in swap and hedge options. Borrowers with multi-currency portfolios can use hybrid facilities that spread exposure across different markets.
Are offshore or corporate structures accepted in cross-border deals?
Yes. In fact, they’re common. Lenders work regularly with offshore entities and SPVs, provided ownership and governance are transparent, and the borrower provides all required legal and compliance documentation.
How can Willow Private Finance assist with international borrowing?
Willow Private Finance coordinates with global lenders and legal partners to arrange cross-border lending for private clients. We handle the complexities of valuation, compliance, and structuring — ensuring that finance aligns with your global portfolio and long-term strategy.
📞 Need Help Securing Cross-Border Finance?
Book a confidential strategy call with one of our private client specialists.
We’ll help you structure lending that crosses borders — without crossing risk boundaries.