E. Inter-American Convention on the Law Applicable to International Contracts 170
170 Part III: Electronic signatures and international contracts buyer is domiciled. Moreover, when elucidating the applicable law, conventions always try to find the country and, therefore, the legal system to which the contract is most closely connected. In this line, whenever the contract is “manifestly more closely connected with a law” other than the one that results from using the domicile connecting factor, the former law is to be applied (Article 8 (3)). The law that results applicable either by the choice of the parties or by application of the rules of the convention may be the law of a non-contracting state (Article 6). The choice of law provisions of the applicable law are to be excluded (Article 15). In addition, the mandatory provisions of the law of the forum are applicable and prevail over the applicable law to the contract (Article 17). The designated law may be excluded only if manifestly incompatible with the public policy of the forum (Article 18). E. Inter-American Convention on the Law Applicable to International Contracts I. Background The Inter-American Convention on the Law Applicable to International Contracts was adopted in Mexico in 1994 with the aim of harmonizing the rules of private international law of the country members of the Organization of American States.563 However, as of this date only two states, Mexico and Venezuela, have ratified the convention. The convention has been in force in these two countries since December 15, 1996.564 II. International contracts The Inter-American Convention on the Law Applicable...
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