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Amwelladmin (talk | contribs) (Created page with "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,...") |
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Latin for “''the law of the place''”. Relevant when contemplating the [[ | Latin for “''the law of the place''”. Relevant when contemplating the [[magic incantation|deep magic]] 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 {{gmsla}}, you ought to have a [[Luxembourg]] law [[pledge]] to go with your English law [[Fixed charge|fixed]] or [[floating charge]]. | In a nutshell, international conventions of [[security]] law say that it is best to have [[security interest|security interests]] governed by the “[[lex situs]]” – the prevailing domestic law where the secured 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 {{gmsla}}, you ought to have a [[Luxembourg]] law [[pledge]] to go with your English law [[Fixed charge|fixed]] or [[floating charge]]. | |||