Licci v. Lebanese Canadian Bank, SAL, 20 N.Y.3d 327

Plaintiffs are U.S., Canadian, and Israeli nationals injured or whose family were harmed by Hizballah rocket attacks during the 2006 Lebanon War while residing in Israel.
Plaintiffs sued Lebanese Canadian Bank (LCB) and American Express Bank (AmEx) in July 2008/January 2009, asserting LCB aided Hizballah via Shahid Foundation in facilitating international monetary transfers.
LCB had no U.S. branches; its only U.S. contact was a New York correspondent account with AmEx used to move funds for Shahid.
District Court dismissed for lack of personal jurisdiction, holding LCB’s NY account maintenance alone was insufficient and there was no nexus to the terrorist attacks.
Second Circuit certified two questions to New York Court of Appeals about CPLR 302(a)(1) and whether the claims arise from LCB’s NY transactions; the court stayed ruling pending certification.
Court of Appeals held both certified questions affirmative, finding that repeated use of the NY correspondent account constitutes transaction of business and that there is an articulable nexus between the NY transactions and the asserted claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does maintaining and using a NY correspondent account constitute transacting business in NY?	Amigo theory: purposeful use creates transaction of business.	LCB: mere maintenance is insufficient to transact business.	Yes; use of the account can satisfy transaction of business.
Do the plaintiffs' claims arise from LCB's NY transactions under CPLR 302(a)(1)?	Second prong satisfied by articulable nexus between NY transfers and harms.	Arise-from linkage is lacking because harms were rockets, not transfers.	Yes; there is an articulable nexus between NY transfers and the pleaded breaches.

Amigo Foods Corp. v. Marine Midland Bank-N.Y., 39 N.Y.2d 395 (1976) (purposeful use of NY correspondent account can satisfy first prong with discovery)
Indosuez Intl. Fin. v. National Reserve Bank, 98 N.Y.2d 238 (2002) (course of dealing in NY supports jurisdiction)
Banco Ambrosiano v. Artoc Bank & Trust, 62 N.Y.2d 65 (1984) (quasi-in-rem jurisdiction via NY correspondent banking)
Ehrlich-Bober & Co. v. University of Houston, 49 N.Y.2d 574 (1980) (agency/contacts through NY bank relations can ground jurisdiction)
Johnson v. Ward, 4 N.Y.3d 516 (2005) (causation not required; relatedness needed for arising-from prong)
Kreutter v. McFadden Oil Corp., 71 N.Y.2d 460 (1988) (articulable nexus standard for arising-from inquiry)
McGowan v. Smith, 52 N.Y.2d 268 (1981) (permissive standard for aris from relationship)
Tamam v. Fransabank S.A.L., 677 F. Supp. 2d 720 (SD.N.Y. 2010) ( ATS dismissal for lack of connection between funds transfers and harms)