Banco Ambrosiano, S.P.A. v. Artoc Bank & Trust Ltd

In Banco Ambrosiano, S.P.A. v. Artoc Bank & Trust Ltd., 62 NY2d 65, 464 N.E.2d 432, 476 N.Y.S.2d 64 [1984]), the Court of Appeals specifically found that the bank account, combined with several other factors were sufficient to meet the lower standard of minimum contacts (Banco at 69). The Court found that it was "nota case in which property is coincidentally located within the State's borders and forms the only relevant link to defendant" (id. at 68). Rather, the account was related to the claim, it was the account where plaintiff was directed by the relevant defendant to deposit the funds, was not an isolated banking transaction but was regularly used by defendant to accomplish its international banking transactions, and defendant frequently communicated with the New York entity with instructions on disbursements (id.). It was only the combination of these factors that allowed the Banco Ambrosiano Court to find quasi in rem jurisdiction.