Just a few years ago, investment and M&A transactions were executed mainly under English law, largely due to the lack of legal regulation of the aspects relative to such transactions in Russia. However, the situation has changed, and nowadays we see a growing number of investors and start-ups working under Russian law. One of the reasons for this is an implementation of some of the well-accepted institutions of English law into the Russian legal system. Thus an article on representations (431.2) («заверения об обстоятельствах») appeared in the Russian Civil Code (became effective) on June 1, 2015.

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