Русско-англо-русский юридический словарь

The functional equivalent of the civil law right of retention is the common law lien. (Cases, Materials and Text on Property Law)

If the obligor has a claim that is due against the obligee under the same legal relationship as that on which the obligation is based, he may, unless the obligation leads to a different conclusion, refuse the performance owed by him, until the performance owed to him is rendered (right of retention). (law.ed.ac.uk)