Choice of Law in International Premarital Agreements. A Comparison Between the US and the European System (Part II)

I have recently published an article in this journal entitled ‘Jurisdiction Clauses in International Premarital Agreements: a comparison between the US and the European system’. The article analyses questions of jurisdiction that arise when contemplating international premarital agreements. It advises giving the parties freedom to choose the competent court, while establishing a series of limitations in order to protect the vulnerable party. It also promotes the idea of extending the analysis to questions of choice of law, which is the aim of the study I present now, conceived as a second part or continuity of the previous article. I will be using the main results achieved in the last article, and some ideas may reappear in this study as I also want it to stand alone.