Project Finance in Civil Law Jurisdictions

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Abstract
This chapter analyses the origins of project financing under civil law since the origins of the concession systems, especially in France, and its influence on the project financing and on the existing legal corpus applicable to public contracts. A large part of the chapter is dedicated to the issues arising from secured lending and to the various types of security interests available in civil law jurisdictions. The authors also describe the OHADA legal system seeking to harmonize business laws in Africa. The OHADA is deeply influenced by French civil law. A recent reform relating to security has incorporated in the OHADA Uniform Act several security interests practised and developed in the last 30 years in France.

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