MОDELS FОR THE INTRОDUCTIОN АND АPPLICАTIОN ОF ENGLISH LАW IN INTERNАTIОNАL FINАNCIАL CENTRES: А CОMPАRАTIVE LEGАL АNАLYSIS

Abstract

This article provides a comparative legal analysis of the models for introducing and applying English law in international financial centres, drawing on the experience of the Dubai International Financial Centre (DIFC), Abu Dhabi Global Market (ADGM), and Astana International Financial Centre (AIFC). In particular, it examines the legal systems that existed in the host states prior to the establishment of these centres, the constitutional and legislative foundations for the application of English law, the hierarchy of legal sources, and the status of judicial precedents. Based on the findings of the study, three models for the application of English law are identified: the autonomous-subsidiary model, the direct-dynamic model, and the mediated-adapted model. The author proposes that the application of English law in international financial centres should be viewed not as a transformation of the host state’s national legal system, but as the establishment of a special legal regime. Such a regime operates within the framework of the relevant financial centre and applies to a specific territory and a defined range of legal relations. Drawing on foreign experience, the article also puts forward practical recommendations for the development of a legal model for the Tashkent International Financial Centre.