No Personal Jurisdiction Over Kenyan Bank Under New Jersey Law Based on Dealings in New York

The World in U.S. Courts: Summer 2013 - Personal Jurisdiction

Community Finance Group, Inc. v. Stanbic Bank Ltd. (U.S. District Court, D.N.J., June 25, 2013)

The plaintiff claimed Defendant Stanbic Bank, a Kenyan corporation, breached its fiduciary duty in a fraudulent gold purchase transaction in Kenya. Jurisdiction over Stanbic Bank in New Jersey was alleged to be based upon the bank’s maintenance of a New York bank account with a Multinational Investment Bank (Germany), which has offices in New Jersey. The court disagreed, finding that even though Stanbic Bank conducted frequent business through the account, maintaining a bank account in New York could not establish that the defendant had “purposefully availed” itself of the privileges of conducting business in New Jersey.

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