Latin American and most European jurisdictions are commonly regarded as civil law jurisdictions. Yet one notable difference between the two is that trust instruments were introduced in Latin America much earlier than in Europe. Panama (1925), Mexico (1926), El Salvador (1926), and Puerto Rico (1928) were pioneers of this development, followed by Venezuela (1956) and Colombia (1971), whereas Argentina (1995) and Uruguay (2003) adopted such instruments at a later stage … (more)
[León Carmona Fontaine, Edinburgh Private Law Blog, 9 April 2026]
See also: Trusts in Latin America and the circulation of legal ideas: Part Two (6 May 2026)
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