The thesis aims to explore the differences between the two Conventions namely the Unidroit Convention on International Factoring and the UNCITRAL Convention on the Assignment of Receivables in International Trade and the effects of American and English laws on these Conventions. In this connection, apart from introduction and conclusion chapters, the thesis contains chapters examining harmonisation of secured transactions laws, applicability policies of these two Conventions, formal validity of assignments under these Conventions, party autonomy provisions, absence of positive liability, debtor protection issues, assignments of bulk and future receivables, anti-assigriment provisions and priority issues. The thesis includes four appendices. These are the texts of the UNCITRAL and Unidroit Conventions, a chart describing the variants on applicability of the UNCITRAL Convention with regard to priority and the current status of these Conventions. The thesis also includes bibliography, table of cases comprised of cases from different jurisdictions and table of contents.
| Identifer | oai:union.ndltd.org:bl.uk/oai:ethos.bl.uk:488421 |
| Date | January 2006 |
| Creators | Akseli, Nazmi Orkun |
| Publisher | University of Manchester |
| Source Sets | Ethos UK |
| Detected Language | English |
| Type | Electronic Thesis or Dissertation |
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