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Conflict of Laws

A guide to researching Conflict of Laws

European Union

Over the course of its history, the European Union has been a center for activity in the area of harmonization of international private law through the development of conventions, directives and regulations. Major initiatives have been in the private law areas of family law, contracts, sales, insurance, trusts and movable property. 

Other useful websites regarding the harmonization of European private law:

Inter-American Specialized Conferences on Private International Law (CIDIPs)

The Specialized Conferences on Private International Law, known by the Spanish acronym CIDIP, are organized under the auspices of the Organization of American States, and demonstrate the Organization's central role in the organization and harmonization of private international law. There have been six conferences so far, which have produced 26 international instruments.

Significant Regional Initiatives

The Organisation pour l'Harmonisation en Afrique du Droit des Affaires (OHADA) started the legal unification process in Africa in October 1992, with the cooperation of the head of states of sixteen OHADA countries. In 1993, its founding treaty was adopted: the Treaty on the Harmonization of Business Law in Africa. Currently, there are seventeen member states, and a number of Uniform Laws have been enacted on subjects including Security Law, General Commercial Law, Arbitration and Company Law. English translations of the Acts are available at the OHADA website.

The Asia-Pacific Economic Cooperation organization (APEC) is another example of regional efforts to confront legal obstacles to international trade and business investment. Founded in 1989, it now counts 21 nations in its membership: Australia, Brunei Darussalam, Canada, Chile, China, Chinese Taipei, Hong Kong, Indonesia, Japan, Korea, Malaysia, Mexico, New Zealand, Papua New Guinea, Peru, Philippines, Russia, Singapore, Thailand, United States, and Vietnam. There is no treaty or other binding commitment, but the frequent meetings of its leaders and exchange of trade information have greatly liberalized trade and international investment in the member states.