An earlier study,' relying upon texts of bilateral loan agreements concluded between Denmark and certain developing countries, 2 and between the United Kingdom and certain developing countries, 3 discloses that there is a need for further examination of the subject for the purposes of updating and assessing the trend of developments in this area of international law. This paper is accordingly designed to offer comparative analysis of the more recent approaches to bilateral loan agreements concluded by Denmark, the United Kingdom and the United States with a number of developing countries. The selection of these three developed, market economy States for the comparative analysis here is based on the realization that their approaches reflect most of the major legal, economic, and policy issues which may be regarded as relevant to loan agreements. At best, their practices offer readily available examples of points which this writer seeks to bring out in connection with the issues enumerated at the end of this introductory section and discussed in the ensuing sections.
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A. O. Adede, “Approaches to Bilateral Loan Agreements between Developed and Developing States: Some Lessons from the Practice of Denmark, the United Kingdom and the United States” (1979) 5:1 DLJ 121.