国外有关律师保守职业秘密规定，都表现为一种法律义务。这在英美法系和大陆法系国家均较明确。律师保密权主要由程序法来规制。需要指出是，大陆法系国家，职业秘密不仅适用于律师与当事人之间的关系，而且适用于所有由于其身份或专业或由于其临时或固定职业而掌握的有关秘密 Foreign lawyers on the provisions of the conservative occupation secrets, have shown a legal obligation. This is more clear in Anglo-American legal systems and civil law countries. The lawyer’s right of confidentiality is mainly regulated by the procedural law. It should be pointed out that in civil law countries, the employment secrets apply not only to the relationship between the lawyer and the client, but also to all the relevant secrets which are due to their status or profession or to their temporary or fixed occupation