Leading Construction Lawyers International Alliance

Doing Business in Civil Law Countries

Globalization of the construction industry is a reality and one that may afford many U.S. contractors significant profit opportunities abroad. Emerging countries often lack the financial resources required to support needed infrastructure projects. As a result, they rely on export credit agencies, the World Bank, or foreign investors who insist upon reputable construction contractors. U.S. contractors can certainly fill those gaps.

As two-thirds of the world follows the civil law system, U.S. contractors should be informed regarding major pitfalls and key areas of concern during the negotiation process in civil law regions, including countries in Europe, Latin America, parts of Africa, and the Middle East. This article discusses a few central contract clauses and the major differences to be mindful of when contracting in civil law countries.