A cross border study of freezing orders and provisional measures: does Mareva rule the waves?

This text compares the law on provisional measures of common law and civil law countries, the goal being to identify and compare their main advantages and disadvantages.

The guiding concept is a well-known statement by the Justices of the US Supreme Court expressed in the famous Grupo Mexicano case, according to which the 'age of slow-moving capital and comparatively immobile wealth' has now passed, and the 21st century requires a fresh look at the law of provisional measures.