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This chapter surveys fiduciary principles in Western European civil law jurisdictions. Focusing on France and Germany, we suggest that functional equivalents to fiduciary duties have developed on the Continent, although they do not always carry exactly the same connotations as their common law...
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of these bodies, the European Union (EU) is involved, though often on a different institutional basis, going from full … membership to observer status; some bodies count all EU Member States among their members whereas others are more limited in … membership.This contribution looks into the role which the EU plays in this area of standard setting for international banking …
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With proponents of deregulation ascendant, both domestically and around the world, private regulation appears to be an attractive solution to a seemingly intractable problem-assuming it is or can be effective. This Article adds an important corrective to standard accounts of private legal...
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This contribution explores the interface between private law, global governance and the EU by focusing on the role that … the EU plays, and should play, in relation to the use of forms of private law-based governance to make them suit public …, this contribution examines how the EU has taken initiatives that put at use or regulate private law-based governance …
Persistent link: https://www.econbiz.de/10013081029
This book examines the law governing asset management in a wide range of commercial contexts across 15 jurisdictions of the European Union. The study includes the basic features of the available legal institutions (for example, whether they provide bankruptcy protection or allow free choice of...
Persistent link: https://www.econbiz.de/10012754430
This is the first English language paper seriously to examine the meaning of subsidiarity from the perspective of private law, in which it might be used to understand legal rules, or the interaction of different kinds of claim. Since there are so few relevant sources in English, this article...
Persistent link: https://www.econbiz.de/10012827942
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