It was suggested I might say what differences were mentioned at last Saturday’s seminar between legal English in England and Wales and in the USA. So this is just a short list, because there weren’t so many things.
Problems: translators into English living in Germany often translate into English that is going to be read in more than one jurisdiction / country
So if I know the verb undertake will confuse people in the USA, I will use agree , which is OK for both BE and AmE
|U.S.A.|England and Wales|
|Names of parties: (The) Buyer / (The) Seller|The Buyer / The Seller|
Translators should write the month out as a word, e.g. 12 July 2003.
(the meaning may be different, but each is used in one country only
Some difference in the meaning of the word covenant?
I think the Americans refer to an entire agreement clause and to warranties and representations – I think we have the phenomenon but use slightly different vocabulary to refer to it.
U.S.: forum and venue, forum shopping
best efforts, at arm’s length
|use of serial comma|OUP uses it and it is permitted in BE, but not many people know that!|
And when you write out a figure in words, apparently the Americans don’t write in words, but just:
|325,000 only (three hundred…)|325,000 (in words: three hundred…)|
It would never have occurred to me that the Americans don’t write ‘in words’!
It was mentioned that the word appearer exists in Australia to refer to the persons appearing before a notary (die Erschienenen). I found it on the Web only in Louisiana, though, which makes sense because they have a partly civil-law system and would have notarial contracts. See, for example, this New Orleans site giving Types of Notarial Acts – the word appearer comes up frequently.