10.01 Consideration of the American courts’ approaches to the ascertainment of the governing law of the beneficiary’s claim for payment against documents tendered under a credit may conveniently begin with the choice of law provisions set forth in section 5-116 of Revised Article 5 that deals with letters of credit under the Uniform Commercial Code and is now statutorily operative throughout the country. Section 5-116 (a) and (b) contain the applicable choice of law precepts. They read as follows: Section 5-116 (a), ‘The liability of an issuer, nominated bank...
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