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Examines the criteria used to determine the law relating to
disputes over letters of credit, where several parties are involved
and each is situated in a different jurisdiction with no choice of
law specified. With letters of credit, there are usually at least
four parties involved, namely the buyer-applicant, the bank issuing
the letter of credit, the seller beneficiary, and the correspondent
bank confirming and advising or negotiating the letter of credit.
These parties may often be situated in different jurisdictions,
having different laws both in substance and procedure. Furthermore,
when incorporated, the letters of credit are governed by the
Uniform Customs and Practice for documentary credits (UCP). While
the UCP is a set of rules and practices on the use of letters of
credit, this particular codification does not offer solutions in
the absence of a choice of law to the problem of conflict of laws
over disputes involving letters of credit. The book contains a
particularly useful documents section, which includes the UCC rules
and samples of letters of credit.
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