METM18 presentation 

Understanding the civil law notary system and how to translate key notary terms into English

Rob Lunn, Barcelona, Spain

Given the difference between the civil and common law notary systems, you find a minefield of non-equivalence when translating notary terms. You can just blindly translate the terms using dictionaries. But the dictionaries don’t always agree, and dictionary entries rarely take you anywhere near to understanding what is actually happening. Why do you need to know what is actually happening? So you can tailor your translation to the context, which is essential for translating non-equivalent terms.
In this talk, I’ll provide some background to help make it easy to translate notary terms. After describing the main differences between common and civil law notaries, I’ll explain what civil law notaries do. I’ll then describe the processes behind key terms like escritura pública and acta notarial and what it means to record a document in public form. Although I’ll use examples from Spanish, I will try to refer to equivalent concepts in other civil law systems. Lastly, I’ll go through a list of safe terms to use in English translations for tricky notary terms you often find in notarial documents.
This talk is aimed at anyone who translates notarial documents or notarial terms appearing in other documents into English. Given how similar the notarial systems are across continental jurisdictions, the talk should be of interest to anyone translating into English from a civil law system.

About the presenter

Rob Lunn is a freelance translator based in Barcelona. He translates from Spanish and Catalan into English and specialises in legal and business translation. As well as being in MET, he is a member of the Chartered Institute of Linguists (CIOL). He has an MA in legal translation, a diploma in translation from the CIOL, and a business degree. You can contact him through his blog Legally Yours from Spain.