L’influence à l’étranger du droit français des affaires [Articol]

Abstract

French business law, although less influential compared to Anglo-Saxon Common Law, has left its mark on world legal history, particularly in the 19ᵉ century with the 1807 Commercial Code, which was exported at the same time as the Napoleonic Civil Code. Unlike the latter, however, the Commercial Code quickly became obsolete with economic change, leading to the adoption of more modern laws in France and elsewhere. Today, France continues to be a source of influence, but much more indirectly and discreetly, through European Union law. In Africa, French law still exerts a significant influence through OHADA, an organisation that harmonises commercial legislation in 17 countries, mainly French-speaking. This model, based on a common legal culture, provides a secure framework for economic development and in turn inspires similar initiatives, notably within European law.