Conflict of Laws and International Finance

Erscheinungsjahr 2007
ISBN: 978-1-84703-207-2
Verlag: Sweet & Maxwell

Buch, Englisch

Examines conflict of law issues in international finance * Gives practical guidance on the conflict of laws from the governing law of contracts to areas such as financial regulation, financial torts, trusts and insolvency * Helps you decide which lega

Autoren/Hrsg.

Wood, Philip R.

Inhaltsverzeichnis

Introduction. Part one – Governing law of contracts. Choice of law and Rome Convention 1980. Scope of governing law. Governing law: foreign currency obligations, exchange controls, embargoes. Governing law: attachments, amalgamations, interest, taxation. Expropriations. Part two – Jurisdiction over financial contracts. Judicial jurisdiction and financial contracts. European Judgments Regulation. Restrictions on judicial jurisdiction. Commentary on financial jurisdiction clauses. Arbitration and financial contracts. Enforcement of foreign judgments. Prejudgment attachments. Part three – Security Interests and Property. Governing law of security interests and other property transfers. Arrest and enforcement jurisdiction. Insolvency conflicts for security interests and property. Part four – Regulation, Torts and restitution in financial law. Regulatory jurisdiction and governing law. Governing law of prospectus liability and other financial torts. Governing law of restitution. Governing law of trusts in financ Insolvency and implementation.