Annotation

The article is devoted to a comparative legal analysis of the institution of out-of-insolvency transaction avoidance in selected Asian and African jurisdictions. Three principal regulatory models are identified: the codified civil law model, the common law model, and the hybrid model. Despite divergences in legal sources and procedural frameworks, a common doctrinal core emerges: transactions carried out with the intent to defraud or prejudice creditors may be set aside outside formal insolvency proceedings, while maintaining the protection of bona fide purchasers. The conclusions of the study may serve as a basis for enhancing Russian legislation in this field.