Lex situs

Latin for “the law of the place”. Relevant when contemplating the magic incantations of taking security over assets in far-off places.

In a nutshell, international conventions of security law say that it is best to have security interests governed by the “lex situs” – the prevailing law where the assets are physically located. So if your assets are held in a tri-party collateral arrangement in Luxembourg, for example, even if your trading contract is an english law 2010 GMSLA, you ought to have a Luxembourg law pledge to go with your English law fixed or floating charge.