The paper in a comparative legal context analyzes the practice of minimizing contractual risks in such countries as England, the United States, Germany, Russia and Uzbekistan. Particular importance is given to the doctrine of estoppel as an effective mechanism of protection of a bona fide counterparty, and the prospects of introducing this tool into the legislation of the Republic of Uzbekistan are examined. The paper is aimed both at lawyers of the sphere and at readers of a wide range as it based on theoretical and practical research.

contract risk assessment system, the principle of good faith, counterparty, bona fide counterparty, estoppel, legal due diligence, impossibility of performance, USREO, “understandable” contract.

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