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Cross-border Transactions of Intermediated Securities - A Comparative Analysis in Substantive Law and Private International Law (Paperback, 2012 ed.)
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Cross-border Transactions of Intermediated Securities - A Comparative Analysis in Substantive Law and Private International Law (Paperback, 2012 ed.)
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This work aims to analyse substantive and conflict of laws rules
regarding intermediated securities in a comparative way. For this
purpose, it examines major jurisdictions' rules for intermediated
securities and the intermediated securities holding systems, such
as the rules of the German, US, Korean, Japanese and Swiss systems,
as well as the relevant EU regimes and initiatives. Above all, it
analyses the two international instruments related to intermediated
securities, i.e. the Geneva Securities Convention and the Hague
Securities Convention. Through a functional comparative approach
based upon legal traditions of the various jurisdictions, this book
gives readers theoretical and practical information on
intermediated securities and their national and international
aspects.
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