Readers, I’d like to bring you up to date on two developments from the Hague Conference.
First, the European Union has finally approved the Convention on Choice of Court Agreements. This had been expected since late last year. Because Mexico has already acceded to the Convention, the Convention will come into force between the EU member states and Mexico on October 1. We are still waiting for action by the US Senate. Singapore signed the Convention earlier this year, so let’s hope it doesn’t beat us to the finish line!
Second, a couple of months ago the Hague Conference approved the new Principles on Choice of Law in International Commercial Contracts. I will have a post on these in the next few weeks, but I wanted to call the Principles to your attention. My plan is to compare the Principles with the relevant sections of the Restatement (Second) on Conflict of Laws, and perhaps some intrepid readers from other legal systems will volunteer to provide their own comparisons. Let me know!