How Trust-Like Is Russia's Fiduciary Management? Answers from Louisiana
33 Pages Posted: 6 Dec 2019
Date Written: September 4, 2019
This article introduces Russia's legal concept of “fiduciary management” - a somewhat equivalent concept to the trust in common legal systems - to American legal audiences. It positions fiduciary management within the spectrum of trust-like devices that have been brought into civilian ambits by way of reference to Louisiana's trust law. After discussing trust operations in Louisiana, this article reviews Russia's experiences with conceptions of trust. Through the prism of Louisiana trust law, this article then analyzes the theoretical underpinnings of fiduciary management in Russia. In further exploration of the degree of operational comparability of fiduciary management to the trust in actual practice, the authors explore examples from Russian jurisprudence. This article concludes with perspectives for the rise of a trust-like device more closely aligned with the Anglo-American template in Russia.
Keywords: Russia law, Louisiana law, civil law, comparative law, trusts, fiduciary management
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