11.01 In Chapter 10, an examination was made of the Anglo-American courts’ mode of application of their contract choice of law rules to ascertain the law applicable to the beneficiary’s claim for payment under a letter of credit. The focus of this chapter is the manner in which they employ the rules to determine what law governs the right of reimbursement of a nominated bank that has honoured or negotiated a supposedly complying set of documents tendered to it. Consideration will also be given to the related issue of the lex situs of a debt incurred by an issuing...
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