Hong Kong: Asymmetrical jurisdiction clause does not satisfy requirement for enabling enforcement in Mainland

In the recent decision of Industrial and Commercial Bank of China (Asia) Limited v Wisdom Top International Limited, the Hong Kong Court of First Instance has decided that an asymmetrical jurisdiction clause commonly seen in international financial documents does not satisfy the requirement of an exclusive jurisdiction clause under the Mainland Judgments (Reciprocal Enforcement) Ordinance (Cap 597). As a result, the judgment creditor cannot benefit from the more efficient way of enforcing a monetary judgment against the debtor in the Mainland.