Since at least the mid 19th century, the English courts have admitted a common law principle of insolvency law referred to in contemporary parlance as the "anti-deprivation rule" (the "ADR"), and known historically as "fraud on the bankruptcy laws"1. The basic premise of the ADR is that a device through which a bankrupt estate is denuded of an asset in fraud of the bankruptcy laws is in essence void as a matter of policy.