Strict Compliance

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When reviewing disputes arising from an issuing bank’s decision to deny payment on a letter of credit, court’s are generally required to apply a strict compliance standard. However, as illustrated in Voest-Alpine International v. Chase Manhattan Bank and Voest-Alpine Trading USA Corp. v. Bank of China, strict compliance can be applied as either a very strict “mirror image” requirement or as a looser conformity standard. Review the above-mentioned cases and briefly describe the facts, discuss which version of strict compliance was applied by the court, and explain why the court in each case applied the version of strict compliance that it did

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