Across the United States (U.S.) jurisdictions, attorney-client privilege broadly protects communications between lawyer and client. This privilege protection extends to a wide array of circumstances, ranging from intra-corporate discussions to discussions involving agents of counsel. While some other common law jurisdictions, such as Israel, have similarly broad attorney-client privilege, internationally many jurisdictions’ rules provide significantly narrower protections. The many differences in the scope and mechanisms of attorney-client privilege across jurisdictions internationally require attorneys representing multi-national clients to take special precautions.
In today’s era of widespread transnational business, investigations, and disputes, it is important for counsel and clients to understand the contours of attorney-client privilege across borders. This article provides a brief overview of the basic attorney-client privilege principles in the U.S., Israel, and the Netherlands to serve as a starting point for understanding the core differences between the legal privilege schemes.
Continue Reading Attorney-Client Privilege: Overview of United States, Israeli, and Dutch Rules