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On February 16, 2021, the United States District Court in the Southern District of New York (the “
Court”) issued a decision
In Re Citibank August 11, 2020 Wire Transfers that upheld the “discharge for value” doctrine and ruled that certain lenders (the “
Defendants”) were entitled to retain funds erroneously sent by the administrative agent (the “
Plaintiff”) under a credit facility to which the Defendants were a party. The decision largely relied upon the application of the facts in this case to precedent established in a 1991 New York Court of Appeals case (
Banque Worms v. BankAmerica International) involving a mistaken wire transfer of $2 million.