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- Title
Cross-border assignment of receivables: conflict of laws in secured transactions.
- Authors
Yuko Nishitani
- Abstract
In the era of globalization, the determination of the law applicable to cross-border assignment of receivables is becoming a crucial issue. In light of highly divergent conflicts rules among various jurisdictions, this paper explores appropriate conflicts rules, with a view to paving the way for a future harmonization. The underlying study examines, in particular, the 2001 UN Receivables Convention, the 2016 UNCITRAL Model Law on Secured Transactions and other relevant instruments including the 2008 Rome I Regulation of the EU, as well as the Japanese, the US and other domestic legal systems in a comparative perspective.
- Subjects
COLLATERAL security; GLOBALIZATION; UNITED Nations Commission on International Trade Law
- Publication
Uniform Law Review, 2017, Vol 22, Issue 4, p826
- ISSN
1124-3694
- Publication type
Article
- DOI
10.1093/ulr/unx052