This Comment addresses a further issue arising from Taurus. It is what (if anything) the Supreme Court decided about the governing law of the contracts contained in a letter of credit and in particular those contracts to which the issuing bank is a party. The point is of importance not only in relation to the factual situation in Taurus itself (concerning a letter of credit issued by the branch of a bank in London advised by an overseas bank to an overseas beneficiary) but also to what might be described as the mirror image of those facts: a letter of credit issued by the branch of a bank overseas through a nominated/confirming bank4 in London where an attachment or injunction is obtained from a court in the jurisdiction of the issuing bank which prevents or purports to prevent the issuing bank from making payment to the nominated bank or to the beneficiary. Traditionally, the English courts have taken a robust approach to such orders. One reason has been that the obligations of the issuing bank to both the beneficiary and the nominated bank are governed by English law and, even if the issuing bank is subject to the overseas court’s jurisdiction, that court order will not as such discharge those obligations as a matter