Letters of credit: model for the illegality exception and for the UCP to address exceptions to the principle of autonomy

This article analyses when illegality is considered as an exception to the principle of
autonomy in documentary letters of credit. It develops a model for illegality exception under English law based on doctrinal study, policy reasons, identified pragmatic problems and expectations of the international business community. The second part of this article argues that it is time for the UCP to nudge national laws toward appropriate outcomes for fraud and illegality exceptions and develops a model based on Cognitive Dissonance Theory, Rational Choice Theory and Nudge Theory.