Traditional “Asset Locks” in non-traditional mixed legal systems: a journey from West to East

Abstract This article endeavors to broaden the discussions through a case study on asset locks that identifies solutions fashioned in four non-traditional mixed jurisdictions. Asset locks are understood here broadly as legal institutions that allow property to be separated, isolated, bound and shielded for designated purposes. Our selection of legal institutions along a journey from West to East includes Louisiana’s trust, Liechtenstein’s foundation, Russia’s fiduciary management, and Irans’ property endowment. After highlighting the essentials of each institution, a comparative screen will explore in more detail how the four sample jurisdictions differ with regard to how a particular asset lock is accomplished.