Comparative Legal Analysis Of Category Management Under The Laws Of The Anglo-Saxon And Continental Legal Family


  • A.A. Albu


confidential property asset management, manager, trustee, beneficiary.


The article analyzes the management category and its civil law form through the use of Anglo-Saxon law and continental legal families. Managing a complex, interdisciplinary category relations in the private sphere covered in the form of asset management and trusts. These two promising private law institutions for all the similarity and proximity of certain characteristics are not identical concepts and came from different sources. Trust law or as it is called Trust is inherent in Anglo-American law, and asset management - Continental. The author investigated and analyzed the law of Great Britain, Russia and Ukraine.

The right choice, the legal definition and interpretation of these institutions needs improvement, as leads to several problems, omissions and conflicts. To do this, first of all, to understand the essence of these concepts knowing their long history and the application in other countries, such as the lack of consistent work can lead to abuse in this area relations.

Based on the research conclusions on improving the legislation of Ukraine.