Your contract says New York law. But in Brazil, it might mean nothing.

You have the contract, the deal is done. But when a dispute arises in Brazil, that 'governing law' clause you insisted on? Courts often ignore it. Brazilian judges default to local law if the contract was formed here.

✗ I signed in São Paulo, but my contract is governed by English law, so English courts apply.

Can I simply choose a foreign law in my Brazilian contract?

DICA

✓ Always include an arbitration clause ✓ Specify the seat of arbitration outside Brazil ✓ Ensure the clause is clear and mandatory

❝ Territoriality traps vanish when you choose the right dispute resolution. Arbitration is your sovereignty clause.

Remember: even with arbitration, the contract's substantive law must not offend Brazilian public policy. A truly international contract requires local expertise to bridge the gap.

Don't let a blind spot in your contract cost you millions.