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Cross-Border Ethics Navigating Conflicting Rules Across Jurisdictions

Master which ethical rules govern your conduct across jurisdictions. Resolve conflicting obligations, protect your license, and navigate double deontology, inequality of arms, and international arbitration disputes with confidence.

2026-05-08 13:00:00

1 hours

Program Details

2026-05-08 13:00:00

2026-05-08 13:00:00

1h CLE Credits

2026-05-08 13:00:00

1 hours

Program Details

2026-05-08 13:00:00

Program Details

2026-05-08 13:00:00

Over 1,000+ webinars

2026-05-08 13:00:00

1 hours

Course Overview

Navigating Conflicting Ethical Rules Across Jurisdictions

2026-05-08 13:00:00

Identify which ethical rules apply when a lawyer’s conduct spans multiple jurisdictions with inconsistent obligations. Apply practical frameworks to resolve conflicts in litigation, transactional work, and international arbitration proceedings.

Format

CLE Credit

1h CLE Credits

Level

Intermediate

Length

1

Key topics that will be covered

01
Multi-Jurisdictional conflicts
Determining applicable ethical rules when a lawyer’s conduct implicates more than one jurisdiction.
02
Double deontology
Situations where a lawyer is subject to conflicting ethical duties across regulatory frameworks.
03
Inequality arms
Lawyers in the same matter operating under different ethical constraints and obligations.
04
Divergent areas
Differences in witness preparation, client communications and confidentiality, and relations among counsel.
05
Applicable rules
Home-state rules, host-state rules, and conflict-of-law approaches reflected in Model Rule 8.5.
06
Arbitration contractarian
International arbitration case study introducing party selection, institutional rules, and tribunal conflict-of-law determination.

Program schedule

clock 1:00 pm - 1:05 pm EST

Conflicts Of Ethical Rules in Multi-Jurisdictional Practice

Explores conflicts between ethical rules governing lawyers practicing across jurisdictions, focusing on how differing professional standards create uncertainty, risk, and strategic challenges, requiring careful navigation to maintain compliance, protect clients, and avoid disciplinary exposure in cross-border representations in modern practice.

Francesca Giannoni-CrystalFrancesca Giannoni-Crystal
clock 1:05 pm - 1:15 pm EST

“Double Deontology” and Exposure to Inconsistent Obligations

Examines the concept of “double deontology” where lawyers face simultaneous duties under multiple ethical systems, exposing them to inconsistent obligations and potential liability, and highlighting the tension between competing professional standards in transnational legal practice contexts and global enforcement environments.

Francesca Giannoni-CrystalFrancesca Giannoni-Crystal
clock 1:15 pm - 1:25 pm EST

“Inequality of Arms” Arising from Differing Ethical Constraints

Analyzes the “inequality of arms” that arises when opposing counsel operate under different ethical constraints, affecting litigation strategy, fairness, and advocacy limits, and raising concerns about procedural balance and the integrity of adversarial proceedings across jurisdictions in cross border settings.

Francesca Giannoni-CrystalFrancesca Giannoni-Crystal
clock 1:25 pm - 1:35 pm EST

Divergences in Specific Areas

Addresses divergences in key areas including witness preparation, client communications and confidentiality, and relations among counsel, illustrating how varying ethical rules shape permissible conduct, strategic choices, and professional responsibilities in cross-border disputes and multi-jurisdictional representations in complex international practice environments.

Francesca Giannoni-CrystalFrancesca Giannoni-Crystal
clock 1:35 pm - 1:45 pm EST

Approaches to Determining the Applicable Rules

Explores approaches to determining applicable ethical rules, including home-state and host-state frameworks, as well as conflict-of-law analyses under Model Rule 8.5, emphasizing practical considerations for resolving uncertainty and managing cross-border professional responsibility issues effectively in diverse legal systems and contexts.

Francesca Giannoni-CrystalFrancesca Giannoni-Crystal
clock 1:45 pm - 1:55 pm EST

International Arbitration as a Case Study

Uses international arbitration as a case study, examining how ethical conflicts play out in practice within a transnational forum, where differing rules and expectations intersect, creating challenges for counsel navigating procedural fairness and professional obligations across jurisdictions and arbitral frameworks.

Francesca Giannoni-CrystalFrancesca Giannoni-Crystal
clock 1:55 pm - 2:00 pm EST

Introduction of the Contractarian Approach and Its Practical Implications

Introduces the contractarian approach, which allows parties and tribunals to define applicable ethical standards by agreement, and examines its practical implications for predictability, party autonomy, and harmonization of professional conduct in international legal proceedings while addressing enforceability concerns and limitations.

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 whose practice bridges Civil Law and Common Law systems, with over two decades of experience advising multinational corporations, law firms, and financial institutions. She focuses on cross-border ethics, international professional responsibility, and multijurisdictional practice issues, often serving as a “lawyer for lawyers” on complex matters involving conflicts of interest, privilege, and professional-conduct compliance. As co-founder of Crystal & Giannoni-Crystal, LLC, she provides guidance on navigating overlapping legal regimes, particularly in international transactions and cross-border representation. She also contributes to advancing education in this field through her work with Technethics, an initiative dedicated to ethics, technology, and global legal compliance.

Education & Credentials

Francesca Giannoni-Crystal is dually qualified as an attorney in the United States and Italy, reflecting her ability to navigate both Common Law and Civil Law systems. Her credentials support a practice focused on international legal ethics, professional responsibility, and cross-border legal compliance.

Recognition & Leadership

Francesca Giannoni-Crystal demonstrates leadership as co-founder of Crystal & Giannoni-Crystal, LLC and through her role in Technethics, an educational platform focused on ethics, technology, and cross-border legal compliance. Her work positions her as a key contributor to the development of best practices in multijurisdictional legal ethics.

Professional Involvement

Francesca Giannoni-Crystal is actively involved in advising law firms and legal professionals on cross-border ethics, conflicts of interest, international privileges, and professional-conduct compliance. Through her work with Technethics, she contributes to education and dialogue on the evolving challenges at the intersection of technology, ethics, and global legal practice.

Experience

Francesca Giannoni-Crystal has over 20 years of experience advising multinational corporations, law firms, and financial institutions on international legal and ethical issues. Prior to co-founding Crystal & Giannoni-Crystal, LLC in 2011 with Professor Nathan M. Crystal, she served as a legal consultant for the Italian Industrial Association and practiced with Deloitte Legal, handling transactional and regulatory matters for global enterprises. She later managed legal affairs for a publicly traded Italian company with subsidiaries across multiple jurisdictions, including the United States, United Kingdom, China, and Brazil, overseeing international contracts, data privacy, and corporate governance. Her work continues to focus on helping attorneys and firms manage risks associated with multijurisdictional professional-conduct rules.
Francesca Giannoni-Crystal

Francesca Giannoni-Crystal

Crystal & Giannoni-Crystal

Francesca Giannoni-Crystal is a dually qualified U.S. and Italian attorney whose practice bridges Civil Law and Common Law systems, with over two decades of experience advising multinational corporations, law firms, and financial institutions. She focuses on cross-border ethics, international professional responsibility, and multijurisdictional practice issues, often serving as a “lawyer for lawyers” on complex matters involving conflicts of interest, privilege, and professional-conduct compliance. As co-founder of Crystal & Giannoni-Crystal, LLC, she provides guidance on navigating overlapping legal regimes, particularly in international transactions and cross-border representation. She also contributes to advancing education in this field through her work with Technethics, an initiative dedicated to ethics, technology, and global legal compliance.

Education & Credentials

Francesca Giannoni-Crystal is dually qualified as an attorney in the United States and Italy, reflecting her ability to navigate both Common Law and Civil Law systems. Her credentials support a practice focused on international legal ethics, professional responsibility, and cross-border legal compliance.

Recognition & Leadership

Francesca Giannoni-Crystal demonstrates leadership as co-founder of Crystal & Giannoni-Crystal, LLC and through her role in Technethics, an educational platform focused on ethics, technology, and cross-border legal compliance. Her work positions her as a key contributor to the development of best practices in multijurisdictional legal ethics.

Professional Involvement

Francesca Giannoni-Crystal is actively involved in advising law firms and legal professionals on cross-border ethics, conflicts of interest, international privileges, and professional-conduct compliance. Through her work with Technethics, she contributes to education and dialogue on the evolving challenges at the intersection of technology, ethics, and global legal practice.

Experience

Francesca Giannoni-Crystal has over 20 years of experience advising multinational corporations, law firms, and financial institutions on international legal and ethical issues. Prior to co-founding Crystal & Giannoni-Crystal, LLC in 2011 with Professor Nathan M. Crystal, she served as a legal consultant for the Italian Industrial Association and practiced with Deloitte Legal, handling transactional and regulatory matters for global enterprises. She later managed legal affairs for a publicly traded Italian company with subsidiaries across multiple jurisdictions, including the United States, United Kingdom, China, and Brazil, overseeing international contracts, data privacy, and corporate governance. Her work continues to focus on helping attorneys and firms manage risks associated with multijurisdictional professional-conduct rules.

Credits by state

AK1.0
AL1.0
AR1.0
AZ1.0
CA1.0
CO1.0
CT1.0
DC
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+

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

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
Approved
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Colorado
Approved
Connecticut
Approved
Delaware
Pending
District of Columbia
No Required
Florida
Approved
Georgia
Approved
Hawaii
Approved
Idaho
Pending
Illinois
Approved
Indiana
Pending
Iowa
Pending
Kansas
Approved
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
Approved
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Approved
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Approved
Texas
Approved
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Approved
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