Tag Archives: Sudan

Case of the Day: Receivers of Sabena v. Deutsche Bank

Sudan Airways

The case of the day is Receivers of Sabena SA v. Deutsche Bank AG (N.Y. App. Div. 2016). Sabena, before it became insolvent, was Belgium’s national airline. It provided airplane maintenance services to Sudan Airways Ltd. In 1997, to pay for some services Sabena had provided for its planes, Sudan Airways initiated an electronic funds transfer for $360,000 with Sabena as the beneficiary. Sudan Airways’s bank was the National Bank of Abu Dhabi. Generale Bank was Sabena’s bank. Bankers Trust, in New York, was the intermediary bank. Its successor-in-interest was Deutsche Bank.

To understand the case, you need to know a little about electronic funds transfers, which are governed by Article 4-A of the UCC (or more precisely in this case, New York’s enactment of the UCC). Here is a brief description that the court quoted in its opinion:
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Case of the Day: Owens v. Sudan

Bombing of the US embassy in Kenya
The bombing of the US embassy in Kenya. Credit: FBI

The case of the day is Owens v. Republic of Sudan (D.D.C. 2015). James Owen and the other plaintiffs were victims of the 1998 US embassy bombings in Africa. Owens had a default judgment against the Republic of Sudan and the Islamic Republic of Iran. Under the FSIA, a default judgment has to be sent to the foreign state using one of the FSIA methods of service before the plaintiff can execute on the judgment. 1 The plaintiffs sought an order determining that a reasonable amount of time had passed and that they had properly given the required notice of the judgment.
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  1. As the judge held, this requirement applies even in state-sponsored terrorism cases, notwithstanding Gates v. Syrian Arab Republic, 755 F.3d 568, 575 (7th Cir. 2014), a case to the contrary.