RT Journal Article SR Electronic T1 Highlights from Securitization News JF The Journal of Structured Finance FD Institutional Investor Journals SP 98 OP 99 DO 10.3905/jsf.2006.644164 VO 12 IS 2 A1 Samantha Rowan YR 2006 UL https://pm-research.com/content/12/2/98.abstract AB For project finance transactions, which take place largely in developing countries that are subject to unstable environments, special attention is required in the drafting of project agreements. In that connection, force majeure events (known also as frustration, impossibility, impracticability, Imprévision and Wegfall der Geschaftsgrundlage) pose a major risk to the success of projects. The fact that the parties to the transaction are generally from different countries, with different legal systems and contract law, requires the drafters of project agreements to be particularly careful, since a contract's enforceability will depend on the language of the provision and how it is triggered according to the law that governs the contract. The article examines how different systems of law (common law, civil law, CISG, Unidroit, and the EU law) and different theoretical approaches to contract law deal with force majeure events and provides practical advice for drafters of project agreements to allocate and minimize that risk.TOPICS: Project finance, legal and regulatory issues for structured finance