CONFLICT OF LAWS ASPECTS OF INTERNATIONAL BONDS TRANSACTIONS

Abstract. This article examines conflict of laws issues related to issue and circulation international bonds at capital markets. It covers characteristic features as financial instruments used for raising from sophisticated investors which determine, in particular, peculiarities solving issues. These include determination the law applicable formal essential validity an bond, rights liabilities between issuer holder bonds, legal status a such questions whether obtains full title transferor how is be transferred, transferee subject or free any defects transferor. The author specifies possible solutions this puzzle that may different competing systems. He argues common some other jurisdictions fundamental lex voluntatis principle also due their contractual nature resulting possibility choose governing bonds. conventional approach proprietary refers situs these securities conclusions formulated end present author’s personal attitude towards solution problems Key words: laws, issuer, law, voluntatis.