Vygovsky A.I. Comparative Analysis of the Methods of Solving of Conflict Aspects Concerning Securities

Abstract: The present article deals with the comparative legal analysis of the legislative approaches to the conflict of laws problem with regard to the intermediated securities. The author scrutinizes the distinct features of relations between the main participants of the indirect holding system, analyzes the doctrinal approaches in this sphere of conflict of laws, examines the legal regulations of various jurisdictions (Belgium, Canada, France, Germany, Italy, Luxembourg, the Netherlands, the United Kingdom, the United States), as well as the European Union law. It also provides an overview of the Hague Convention 2002 on the Law Applicable to Certain Rights in Respect of Securities Held with an Intermediary

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