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Ethical Duties and Practical Issues in Notarization for International Transactions

A signature notarized in the United States can be refused abroad, and a foreign public instrument can fail at home. Learn to plan inbound and outbound documents, choose between apostille and legalization, coordinate foreign counsel and notaries, and meet Model Rules 1.1 through 5.3.

2026-11-03 14:30:00

Program Details

2026-11-03 14:30:00

2026-11-03 14:30:00

1h CLE Credits

2026-11-03 14:30:00

Program Details

2026-11-03 14:30:00

Program Details

2026-11-03 14:30:00

Over 1,000+ webinars

2026-11-03 14:30:00

Course Overview

A U.S. notary’s stamp is not a civil-law notary’s authentic instrument

2026-11-03 14:30:00

Common law and civil law notaries hold different roles and authority. One notarizes a signature; the other executes an authentic instrument. Electronic notarization, remote online notarization, and e-Apostilles now add a second layer of recognition questions on top of that divide.

Miss the difference, and a power of attorney is rejected overseas. Skip the apostille or legalization, and the deal stalls. Hand a document to a foreign notary without planning, and client information is exposed. Each misstep tests the duties of competence (Rule 1.1), diligence (Rule 1.3), communication (Rule 1.4), confidentiality (Rule 1.6), and nonlawyer assistance (Rule 5.3).

Through practical examples, attendees leave with a plan for inbound and outbound documents, a method for coordinating foreign counsel, notaries, and service providers, language for telling clients about likely obstacles, and the judgment to avoid unnecessary costs, delays, and risks.

Format

CLE Credit

1h CLE Credits

Level

Intermediate

Length

1

Key topics that will be covered

01
Ethical Duties Abroad
How Model Rules 1.1, 1.3, 1.4, 1.6, and 5.3 govern identifying foreign-law issues and coordinating with foreign professionals in an international transaction.
02
Common Law vs. Civil Law Notaries
How the distinction between notarizing a signature and executing an authentic instrument changes what a document can do in another country.
03
Apostille or Legalization
How to choose the authentication path that gets a document recognized across borders, and when translations are required.
04
Public and Private Instruments
How powers of attorney and the distinction between public and authenticated private instruments drive formal requirements.
05
Inbound and Outbound Planning
How to plan documents in both directions, reduce rejection, safeguard confidential information, and communicate obstacles to clients.
06
Remote and Electronic Notarization
How electronic notarization, remote online notarization, and e-Apostilles are recognized and accepted in international transactions.

Program schedule

clock 2:30 pm - 3:30 pm EST

Ethical Duties and Practical Issues in Notarization for International Transactions

This program examines attorneys’ ethical responsibilities in handling notarization and document authentication in international transactions, particularly the duties of competence (ABA Model Rule 1.1), diligence (Rule 1.3), communication (Rule 1.4), confidentiality (Rule 1.6), and responsibilities regarding nonlawyer assistance (Rule 5.3). It explores the fundamental differences between notaries in common law and civil law jurisdictions and the practical difficulties these differences create when documents executed in one country must be used in another. The program will address the authentication and recognition of foreign documents, including apostilles and legalization, as well as common problems involving powers of attorney, public instruments, translations, and other formal requirements. Through practical examples, the program will discuss how attorneys can anticipate and resolve these issues, coordinate effectively with foreign counsel, notaries, and other service providers, safeguard client information, communicate with clients about potential obstacles, and avoid unnecessary costs, delays, and risks.

Francesca Giannoni-CrystalFrancesca Giannoni-Crystal
Francesca Giannoni-Crystal

Francesca Giannoni-Crystal

Crystal & Giannoni-Crystal

Francesca Giannoni-Crystal

Francesca Giannoni-Crystal

Crystal & Giannoni-Crystal

Francesca Giannoni-Crystal is a dually-qualified U.S. and Italian attorney and the co-founder of Crystal & Giannoni-Crystal, LLC, a “lawyers for lawyers and international matters” boutique. She acts as a lawyer for lawyers, helping firms bridge civil law and common law systems, handle cross-border ethics questions, support international litigation, and close international transactions. She is co-author of Do the Right Thing (for your duty of competency): Some Ethical and Practical Thoughts on “Notarization” in International Transactions, published in Global Jurist in 2012.

Education & Credentials

Ms. Giannoni-Crystal holds two Juris Doctor degrees: one from the University of Florence, Italy, where she graduated with maximum grades (110/110), and one from the Charleston School of Law, where she graduated cum laude. She also earned an LLM in Air and Space Law, summa cum laude, from the University of Mississippi School of Law. She is admitted as an attorney in New York and the District of Columbia, as an avvocato in Italy, and as a foreign legal consultant in South Carolina (not a member of the SC Bar), and she is admitted to the United States District and Bankruptcy Courts for the District of Columbia. She works in Italian and English at native proficiency, Spanish at full working proficiency (DELE C1 certified), and German at professional working proficiency, with additional French, Portuguese, Mandarin Chinese, and Hebrew.

Recognition & Leadership

She serves as vice chair and policy officer of the International Ethics Committee of the ABA Section of International Law and sits on the New York State Bar Association’s Committee on Standards of Attorney Conduct (COSAC), where she served on the subcommittee that drafted the report on a proposed rule for temporary practice of law and in-house counsel in New York, approved by the NYSBA House of Delegates in November 2015. She is the former Vice Chair of the International Law Committee of the South Carolina Bar and served on its subcommittee recommending limited admission to practice for foreign lawyers, a proposal the SC Bar House of Delegates approved and submitted to the SC Supreme Court. For the 2012–2013 bar year she was Vice-Chair and publications officer of the Europe Committee of the ABA Section of International Law, and she has served on the Committee on Foreign & Comparative Law of the New York City Bar Association. She is rated by Super Lawyers and is co-responsible for Technethics (www.technethics.com), a database, blogging, and training platform on ethics, technology, and privacy.

Professional Involvement

Ms. Giannoni-Crystal is a member of the American Bar Association, including its International Section and the Professional Responsibility Committee of its Business Law Section; the Ordine degli Avvocati di Firenze; the New York State Bar Association and its International Section; the New York City Bar Association; the District of Columbia Bar; The Bar Association of the District of Columbia; the Women’s Bar Association of the District of Columbia; and the Charleston County Bar Association.

Experience

Her practice centers on transactional work and contractual issues, including commercial law, banking law, Internet law, business law, international transactions, mergers and acquisitions, company formation and reorganization, financing, and property development. On general retainer with the legal office of a major Italian listed company in Internet and mobile value-added services, she carried direct responsibility for the legal issues of the group’s foreign companies in the United States, the United Kingdom, Spain, China, Brazil, and Argentina, establishing branches and offices worldwide and drafting and negotiating international commercial agreements. Working with local lawyers, she has assisted Italian companies with business formations and operations in Spain, Germany, France, the Czech Republic, Portugal, the United Kingdom, Mainland China, Hong Kong, India, Indonesia, Australia, the United States, Brazil, and Argentina. Earlier she was a legal consultant to the Italian Industrial Association and an attorney with Deloitte Legal before opening her own practice; in 2011 she co-founded Crystal & Giannoni-Crystal, LLC with Nathan M. Crystal.

Her writing on cross-border practice and ethics includes Choice of Law in Lawyers’ Engagement Agreements (121 Penn St. L. Rev. 683, 2017), Choice of Law and Risk Management for Conflicts of Interest (Charleston Law Review, 2022), Using Occam’s Razor to Solve International Attorney-Client Privilege Choice of Law Issues (41 N.C. J. Int’l L. 276, 2016), “One, No One and One Hundred Thousand” … Which Ethical Rule to Apply? Conflict of Ethical Rules in International Arbitration (32 Miss. C.L. Rev. 283, 2013), Enforceability of Forum Selection Clause: A “Gallant Knight” Still Seeking Eldorado (8 S.C. J. Int’l L. & Bus. 203), and Understanding Akzo Nobel (Global Jurist, 2011). She has also written on cloud computing for lawyers across U.S. and EU approaches, on the Internet of Things and data protection in the EU and the U.S., and, more recently, on data processing in space and the GDPR and a series of space law articles in the Journal of Air Law and Commerce, the Journal of Space Law, the Harvard National Security Journal, and the Georgia Journal of International and Comparative Law.
Francesca Giannoni-Crystal

Francesca Giannoni-Crystal

Crystal & Giannoni-Crystal

Francesca Giannoni-Crystal is a dually-qualified U.S. and Italian attorney and the co-founder of Crystal & Giannoni-Crystal, LLC, a “lawyers for lawyers and international matters” boutique. She acts as a lawyer for lawyers, helping firms bridge civil law and common law systems, handle cross-border ethics questions, support international litigation, and close international transactions. She is co-author of Do the Right Thing (for your duty of competency): Some Ethical and Practical Thoughts on “Notarization” in International Transactions, published in Global Jurist in 2012.

Education & Credentials

Ms. Giannoni-Crystal holds two Juris Doctor degrees: one from the University of Florence, Italy, where she graduated with maximum grades (110/110), and one from the Charleston School of Law, where she graduated cum laude. She also earned an LLM in Air and Space Law, summa cum laude, from the University of Mississippi School of Law. She is admitted as an attorney in New York and the District of Columbia, as an avvocato in Italy, and as a foreign legal consultant in South Carolina (not a member of the SC Bar), and she is admitted to the United States District and Bankruptcy Courts for the District of Columbia. She works in Italian and English at native proficiency, Spanish at full working proficiency (DELE C1 certified), and German at professional working proficiency, with additional French, Portuguese, Mandarin Chinese, and Hebrew.

Recognition & Leadership

She serves as vice chair and policy officer of the International Ethics Committee of the ABA Section of International Law and sits on the New York State Bar Association’s Committee on Standards of Attorney Conduct (COSAC), where she served on the subcommittee that drafted the report on a proposed rule for temporary practice of law and in-house counsel in New York, approved by the NYSBA House of Delegates in November 2015. She is the former Vice Chair of the International Law Committee of the South Carolina Bar and served on its subcommittee recommending limited admission to practice for foreign lawyers, a proposal the SC Bar House of Delegates approved and submitted to the SC Supreme Court. For the 2012–2013 bar year she was Vice-Chair and publications officer of the Europe Committee of the ABA Section of International Law, and she has served on the Committee on Foreign & Comparative Law of the New York City Bar Association. She is rated by Super Lawyers and is co-responsible for Technethics (www.technethics.com), a database, blogging, and training platform on ethics, technology, and privacy.

Professional Involvement

Ms. Giannoni-Crystal is a member of the American Bar Association, including its International Section and the Professional Responsibility Committee of its Business Law Section; the Ordine degli Avvocati di Firenze; the New York State Bar Association and its International Section; the New York City Bar Association; the District of Columbia Bar; The Bar Association of the District of Columbia; the Women’s Bar Association of the District of Columbia; and the Charleston County Bar Association.

Experience

Her practice centers on transactional work and contractual issues, including commercial law, banking law, Internet law, business law, international transactions, mergers and acquisitions, company formation and reorganization, financing, and property development. On general retainer with the legal office of a major Italian listed company in Internet and mobile value-added services, she carried direct responsibility for the legal issues of the group’s foreign companies in the United States, the United Kingdom, Spain, China, Brazil, and Argentina, establishing branches and offices worldwide and drafting and negotiating international commercial agreements. Working with local lawyers, she has assisted Italian companies with business formations and operations in Spain, Germany, France, the Czech Republic, Portugal, the United Kingdom, Mainland China, Hong Kong, India, Indonesia, Australia, the United States, Brazil, and Argentina. Earlier she was a legal consultant to the Italian Industrial Association and an attorney with Deloitte Legal before opening her own practice; in 2011 she co-founded Crystal & Giannoni-Crystal, LLC with Nathan M. Crystal.

Her writing on cross-border practice and ethics includes Choice of Law in Lawyers’ Engagement Agreements (121 Penn St. L. Rev. 683, 2017), Choice of Law and Risk Management for Conflicts of Interest (Charleston Law Review, 2022), Using Occam’s Razor to Solve International Attorney-Client Privilege Choice of Law Issues (41 N.C. J. Int’l L. 276, 2016), “One, No One and One Hundred Thousand” … Which Ethical Rule to Apply? Conflict of Ethical Rules in International Arbitration (32 Miss. C.L. Rev. 283, 2013), Enforceability of Forum Selection Clause: A “Gallant Knight” Still Seeking Eldorado (8 S.C. J. Int’l L. & Bus. 203), and Understanding Akzo Nobel (Global Jurist, 2011). She has also written on cloud computing for lawyers across U.S. and EU approaches, on the Internet of Things and data protection in the EU and the U.S., and, more recently, on data processing in space and the GDPR and a series of space law articles in the Journal of Air Law and Commerce, the Journal of Space Law, the Harvard National Security Journal, and the Georgia Journal of International and Comparative Law.

Credits by state

AK1.0
AL1.0
AR1.0
AZ1.0
CA1.0
CO1.0
CT1.0
DC1.0
DE1.0
FL1.0
GA1.0
HI1.0
IA1.0
ID1.0
IL1.0
IN1.0
KS1.0
KY1.0
LA1.0
MA1.0
MD1.0
ME1.0
MI1.0
MN1.0
MO1.2
MS1.0
MT1.0
NC1.0
ND1.0
NE1.0
NH60.0
NJ1.0
NM1.0
NV1.0
NY1.0
OH1.0
OK1.0
OR1.0
PA1.0
RI1.0
SC1.0
SD1.0
TN1.0
TX1.0
UT1.0
VA1.0
VT1.0
WA1.0
WI1.0
WV1.2
WY1.0

1000+

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Access to live webinars & recordings

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Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

10,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

MCLE Credits

Alabama
Pending
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Colorado
Pending
Connecticut
Approved
Delaware
Pending
District of Columbia
No Required
Florida
Approved
Georgia
Pending
Hawaii
Approved
Idaho
Pending
Illinois
Pending
Indiana
Pending
Iowa
Pending
Kansas
Pending
Kentucky
Pending
Louisiana
Pending
Maine
Pending
Maryland
No Required
Massachusetts
No Required
Michigan
No Required
Minnesota
Pending
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Pending
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Carolina
Pending
North Dakota
Approved
Ohio
Pending
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Approved
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Pending
Texas
Approved
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Pending
Wyoming
Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs