Document Type : Original Article
Authors
1
Department of Law, Go. C. Islamic Azad University, Gorgan, Iran.
2
Department of Law, Payame Noor University, Tehran, Iran.
3
Department of Private Law, Go. C., Islamic Azad University, Gorgan, Iran.
10.22091/ijicl.2025.12749.1152
Abstract
Conciliation contracts are of great importance in international systems and are considered as an important tool for solving financial problems in a way that they contribute significantly to economic prosperity by preventing the complete dissolution of economic units. Therefore, a comparative study of conciliation contracts in different legal systems such as Iran, the United States and the United Kingdom can contribute significantly to the reform of commercial law laws and regulations in this field. Accordingly, the main purpose of the present study is to study the economic policies and challenges in conciliation contracts and to apply this issue in the legal systems of Iran, the United States and the United Kingdom. The main question of the present study is: "What is the main challenge of conciliation contracts in the legal systems of Iran, the United States and the United Kingdom?" In response, it can be hypothesized that the major challenge in the US and Iranian systems seems to be debt security, while in the UK, credit restoration is considered a major challenge. The research findings indicate that in all three countries, from a political perspective, composition agreements play a vital role in resolving debts and rebuilding the financial situation of debtors, but each of these countries faces its own challenges. In Iran, there are problems such as lack of transparency in assets and resistance from some creditors. In the US, challenges such as legal complexities and problems related to creditor cooperation are relevant. Despite a modern legal framework, the UK also faces issues such as administrative complexities and economic impacts of composition agreements. Given the problems in all three systems, it is suggested that political and legal reforms be carried out to facilitate the process of composition agreements in all three countries.
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