Abstract
As an unfortunate legacy of developments that unfolded during the nineteenth century, choice of law in international contracts has become chaotic, characterized by conflicting solutions around the world. Europe has been at the forefront in effectively addressing the problem and trying to solve it, currently through a regulation in force in the European Union. The Americas have been less fortunate, with the aggravation that in the region there is a strong civil and common law division, which adds complexity to the matter. This presentation outlines the efforts undertaken in the Americas to tackle this problem and describes recent developments that offer a promising scenario for the region in the near future.
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