In the modern world, corporations engage in international business transactions as a matter
of course. A US manufacturer based in New York agrees to sell mining equipment to a Swiss
firm. A British lender agrees to finance a South African corporation's purchase of a
commercial airliner. A German bank agrees to purchase at a discount the accounts
receivable of a Dutch automobile company. In these transactions, the parties must grapple
with an array of risks. One of these is the risk of legal uncertainty, or the risk of being forced …

In international commercial transactions, it is not always clear which state's law will apply to
govern a particular contract. Historically, states have sought to address this problem by
means of two types of treaties. The first aims to solve the problem by bringing about the
substantive unification of commercial law across multiple jurisdictions; once the law is
everywhere the same, then it no longer matters which state's law applies to govern the
contract. The second aims to solve the problem in part by empowering the transacting …