ABSTRACT
The doctrine of strict compliance has governed the law of letters of credit since the beginning of the twentieth century. An ardent supporter—inspired by the rhetoric of old and new authorities—may describe strict compliance as a stronghold of the law of letters of credit. It would be inaccurate to assert that “strict compliance” is used solely, or even primarily, as a bargaining device by importers. “Strict compliance” is a defence raised where the importer discovers that the goods shipped are defective or that the exporter has perpetrated a fraud involving, for instance, the shipment of rubbish or the tender of false or fraudulent documents. It is clear that the decision in Kredietbank Antwerp militates against any future attempts to apply a “mirror image” test as the yardstick of strict compliance. In respect of documentary or commercial credits, the courts and the business world developed principles that are used to combat strict compliance.
