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  • The Law Governing Letters o...
    Anthea Markstein

    Auckland University law review, 01/2010, Volume: 16
    Journal Article

    The three main policy considerations that underpin the determination of the law governing letters of credit in the absence of choice are discussed. The most appropriate outcome, given the current law and the commercial realities, would be for the courts either to adopt the fresh agreements approach based on an implied choice of law, or to establish a fixed law in the context of freely negotiable letters of credit.