Русско-англо-русский юридический словарь

In the United States, a liquidated damage clause is intended to estimate damages in the event of non-performance or breach of contract. [...] The intent of liquidated damages is simply to measure damages that are hard to prove once incurred. If the liquidated damages are disproportionate, they can, however, be declared a penalty. The clause is then void, and recovery will be limited to the actual damage that results from the breach. [...]

In civil law countries, the attitude toward contractual penalties is quite different from the common law approach. The Napoleonic Code, upon which most civil codes are based, allowed for penalties to encourage performance of contractual obligations. (This is the precise rationale that is rejected in the United States.) (lexology.com)

Authors’ rights are a part of copyright law. The term is a direct translation of the French term droit d’auteur (also German Urheberrecht), and is generally used in relation to the copyright laws of civil law countries and in European Union law. (Wikipedia)

A wrong (from Old English wrang – 'crooked')[1] is an act that is illegal or immoral.[2] Legal wrongs are usually quite clearly defined in the law of a state and/or jurisdiction. They can be divided into civil wrongs and crimes (or criminal offences) in common law countries,[2] while civil law countries tend to have some additional categories, such as contraventions. (Wikipedia)

First, civil law countries distinguish only between dolus (intent) and culpa (negligence), whereas American criminal law distinguishes between purpose, knowledge, recklessness, and negligence. (Mens Rea in Comparative Perspective)