Procuração/power of attorney

This paper presents a contrastive legal and corpus-based linguistic and terminological analysis to translate a common legal instrument on a global scale, the power of attorney in English or procuração in Portuguese. This usually takes the shape of a written document, granted before a notary public as required by law, allowing one person to appoint another person to act on his/her behalf. Civil law and common law systems differ considerably with respect to requirements, formalities and range of powers permitted. In cross-border transactions, a translation is required to certify the authority given to third parties who do not speak the language. Bearing this in mind, a comparable corpus of authentic Portuguese and British texts (from England and Wales, and Northern Ireland) pertaining to this legal genre (12 procurações and 24 PoA) is analysed to identify its characteristics at functional, situational, thematic, lexical and grammatical levels.