The work is devoted to the issues of determining jurisdiction and applicable law when bringing persons to subsidiary liability in the context of cross-border insolvency. The questions of delimiting the competence of the courts of the main and secondary proceedings are considered, and potential conflict-of-laws rules are analyzed. The author substantiates the thesis on the need to concentrate disputes over bringing controlling persons to liability in the court handling the bankruptcy case, taking into account the specifics of such proceedings. A conclusion is drawn about the expediency of applying the law of the state of the court conducting the insolvency proceedings.