Tag: choice of law
Courting Brexit – jurisdiction and choice of law
This blog aims to provide a brief overview of the potential impact of Brexit with regard to the UK’s civil judicial cooperation with the other European Union Member States, in particular with respect to jurisdiction, recognition, enforcement and choice of law, with some added commentary on the impact on derivatives transactions. In brief, the UK’s […]
ISDA- exclusively yours
ISDA has released new model clauses and non-binding guidance in respect of Section 13 (a) and (b), dealing with choice of Governing Law and choice of court. The 15 page 2018 Choice of Court and Governing Law Guide (“the Guide”) contains the following: New exclusive jurisdiction model clauses. One in favour of the English courts, another […]
Dexia v Comune di Prato (2017) – When in Rome, do as the Court of Appeal says
Dexia Crediop SPA v Comune di Prato [2017] EWCA Civ 428, and subsequent UKSC refusal of leave to appeal On 18 January the Supreme Court closed the curtain on the long-running Dexia Crediop SpA v Comune di Prato saga. The Court refused leave for the municipality (Prato) to appeal the 15 June 2017 Court of […]