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Review of Some Aspects of the Russian Legislation on Fiduciary Management of Property and Personal Funds through the Prism of the Law on Trusts in the United States and Canada

Enactment of new provisions of the Civil Code in the spring of 2022 on personal funds has increased the number of legally recognized instruments for management of property of others available in Russia (personal funds, investment funds of closed type and trust management agreements). This article reviews similarities between these three instruments and trusts formed under applicable laws of the United States and Canada. Such similarities suggest that certain legal mechanisms and approaches to legal issues developed in the United States and Canada should be taken into account for further development of the Russian law on personal funds and implementation of the law in practice. The article analyses certain aspects of the Russian legislation on management of property of others (legal status of each instrument, liability of the managers to the beneficiaries and liability of founders of personal funds for the obligations of such funds) and compares provisions of Russian law with relevant laws of the State of New York and the Province of Quebec.