In Casey v. U.S. Nat. Bank Assn. (2005) 127 Cal.App.4th 1138, a bankruptcy trustee sued several banks for aiding and abetting a fraudulent scheme to loot the debtor corporation. (Casey, supra, 127 Cal.App.4th at p. 1141.) In reversing, the court found that the trustee's allegations fell "far short" of the requirements for pleading a cause of action for aiding and abetting breach of fiduciary duty. (Id. at p. 1148.) Although the complaint provided "ample details of the banks' improper conduct in their business dealings with the perpetrator of the fraud, the complaint failed to establish that the banks had actual knowledge of the primary violation in which they purportedly participated." (Ibid.) It was insufficient for the trustee to allege that "the banks knew something fishy was going on . . . ." (Id. at p. 1149.) In Casey, the court explained that the defendant banks' knowledge of suspicious account activities, even money laundering, did not give rise to tort liability. (Casey, supra, 127 Cal.App.4th at p. 1151.) Casey makes clear that if a plaintiff can allege that the defendant banks knew that its account holders (fiduciaries of a corporation) were stealing corporate funds and knowingly assisted them in laundering this stolen money, such allegations would suffice to state a claim for aiding and abetting theft or breach of fiduciary duty. (Id. at pp. 1151-1152.)