A comparative analysis of the civil law and the common law on fraud in the commercial letter of credit

  • David Felipe Arellano de Figueiredo (Student)

Student thesis: Master's Thesis


The commercial letter of credit is one of the most commonly used methods of payment in international trade, and it is normally used to finance trade of commodities, such as oil and other raw materials from the emerging economies in Asia, Africa and Latin America because of its inherent security. This paper is focused on the legal differences among the Civil and the Common Law regarding fraud on letters of credits, specifically between the law of the United States of America, the United Kingdom of the Great Britain and Ireland and Canada; and the Kingdom of Spain, the Portuguese Republic and the French Republic.
Date of Award2009
Original languageEnglish
Awarding Institution
  • Universidade Católica Portuguesa
SupervisorJonathan C. Carlson (Supervisor)


  • Fraud
  • Strict compliance
  • Autonomy
  • Evidence
  • Measures to prevent payment
  • Innocent claimants


  • Mestrado em Direito

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