Legal Regulation of Sovereign Bonds in Private International Law

Trading in bonds constitutes a significant amount of total trading on the Moscow Stock Exchange, which indicates the demand for the use of a debt financial instrument. However, despite this, the legal regulation of the cross-border circulation of bonds in Russia is clearly lagging behind the existing economic realities. In the cross-border circulation of bonds, when the bond legal relations complicated by a foreign element, issues of determining applicable law arise, since the nationality of issuers, investors and intermediaries may be different. The study analyzed the regulation of conflict-of-laws and substantive rules at both the international and national levels to determine the main approaches to unification and identify the most effective conflict-of-laws bindings, key features in the circulation of bonds. The study also concerns the issue of defining government bonds as an investment in international commercial arbitration to protect the rights of sovereign bondholders.