Trusts and Latin America- A Walk Down Memory Lane.

The English trust has always been a flexible and resilient creature, and not more so than in its application and survival in Latin America. Because all South American countries are civil law jurisdictions and adopted the Napoleonic code in one way or another, and because Napoleon was hostile to the ancien regime, which before the French Revolution used trusts to entail their land and great estates, trusts had no place in Latin America. Instead the great landowners tied up their land as the primary source of wealth, just as effectively, under the latifunda system.