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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 2/2025: Abstracts

Conflict of Laws

had to deal with the extraterritorial effect of so-called US secondary sanctions on contracts to which German law is applicable. Faced with such a scenario in UniCredit v RusChem, the UK Supreme Court strengthened the protective role of the English courts over contracts governed by English law that contain arbitration agreements.