To embed, copy and paste the code into your website or blog: 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.