Hong Kong generally has followed English legislation, but English insolvency laws and the approach they prescribe are more alien to the pragmatic Chinese business community than are other commercial laws. As a result, Chinese businesses in Hong Kong often have adhered to their own informal rules of compromise without resorting to the formality of the legal system. In addition, as an island surrounded by countless independent jurisdictions and founded on freedom of trade, troubled assets and cash can be moved out of Hong Kong more quickly than from elsewhere, so solutions that are more practical than formal processes often are required. A Potpourri in Singapore Singapore reflects a more diverse, multicultural background. There is Malay law and custom that has aspects of Islamic law.
Islamic law governs the Muslim community.
Some Chinese custom still applies. Superimposed on these is the subsequent English common and statutory law that found its way to Singapore via Malaysia, whose law, in turn, was founded on Australian law derived from the laws of England. Unlike Hong Kong, Singapore has introduced a form of judicial management modeled after English insolvency laws. Under this scheme, a company can obtain a moratorium, allowing it to put in place a creditors' plan. That episode brought about a greater acceptance of the idea of a formal workout in Singapore, and lessened, but did not eliminate, the stigma commonly attached to insolvency in Asia.