ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
Home Uncategorized

U.S. Supreme Court declines to review Fourth Circuit ruling limiting beneficiary bank liability for fraudulent transfers

November 3, 2025
Reading Time: 3 mins read
U.S. Supreme Court curbs universal injunctions

Fraudulent transfers
Studco Building Systems U.S. LLC v. 1st Advantage Federal Credit Union
Date: Oct. 6, 2025

Issue: Whether a financial institution can be held liable under UCC 4-207 for processing a fund transfer when the beneficiary name and account number do not match, without having actual knowledge of the discrepancy.

Case Summary: The U.S. Supreme Court declined to review a Fourth Circuit decision that ruled a credit union was not liable for a wire transfer in a business email compromise scam case where the credit union lacked “actual knowledge” of the mismatch between the account number and beneficiary.

In 2018, an unknown third party impersonating Olympic Steel sent Studco a fraudulent email instructing it to update Olympic Steel’s banking information. The scammers provided an account number they controlled. Believing the request was legitimate, Studco made four ACH payments to the account at 1st Advantage, listing Olympic Steel as the beneficiary. In reality, the funds went to an account owned by someone else who had also fallen victim to the scheme.

1st Advantage’s monitoring platform for ACH transfers automatically generated warnings for ACH transactions when the payee identified by the party transmitting the funds did not exactly match the name of the customer holding the account receiving the funds. The platform generated hundreds to thousands of warnings related to mismatched names on a daily basis, but the system notified no one when a warning was generated, nor did 1st Advantage review the reports.

In 2019, Studco sued 1st Advantage, alleging it failed to follow basic security procedures and should have rejected the transfers. Judge Raymond Jackson of the Eastern District of Virginia ruled for Studco, concluding the credit union would have discovered the mismatch between the intended payee and the recipient if it had exercised due diligence.

On appeal, a Fourth Circuit panel reversed, ruling financial institutions bear no liability for fund transfers when the beneficiary’s name and account number do not match, unless the institution had “actual knowledge” of the mismatch at the time of transfer. Rejecting the district court’s “knew or should have knew” standard, the Fourth Circuit emphasized the standard for assessing liability under UCC 4A-207 for beneficiary banks is actual, subjective knowledge. The Fourth Circuit also observed that 1st Advantage processed hundreds to thousands of transactions each day, making manual review impractical, and that it followed standard practice by relying on the account number Studco supplied.

On July 18, 2025, Studco petitioned the U.S. Supreme Court to review the case, claiming that the circuits disagree on how to interpret UCC Section 4A’s knowledge standard. Studco argued that Section 4A-207 makes a beneficiary bank liable when it would have discovered a mismatch through due diligence. Studco argued the Fourth Circuit abused its discretion by refusing to remand the case for the district court to apply the “actual knowledge” standard. Studco also argued that courts disagree on whether Section 4A-207 requires privity, which establishes a direct contractual or legal relationship between parties. Still, the Supreme Court declined to review the case and offered no additional comment.

Bottom Line: The Supreme Court let stand a Fourth Circuit ruling that shields banks from liability for fraudulent fund transfers unless they had actual knowledge that the beneficiary’s name and account number did not match.

Document:
Fourth Circuit opinion
Petition

Tags: Banking Docket
ShareTweetPin

Related Posts

Compliance question of the month: February 2025

Compliance question of the month: June 2026

Uncategorized
June 8, 2026

My bank offers a consumer checking account product titled "Free Checking." This product currently has no maintenance or activity fees, and no minimum balance or transaction requirements. The bank is considering adding a nominal monthly paper statement fee...

Recent news from Treasury’s Office of Foreign Assets Control: April 5

Recent news from Treasury’s Office of Foreign Assets Control: June 8

Uncategorized
June 8, 2026

News items that are the most recent sanctions-related actions from the Office of Foreign Assets Control.

Fed report: Banking system remains strong, assessing of fintech risk ramps up

ABA files amicus brief urging Second Circuit to review Fed board’s denial of Canandaigua’s Cash Guarantee Mortgage Program

Uncategorized
June 2, 2026

ABA filed a coalition amicus brief urging the Second Circuit to review the Fed board's decision denying Canandaigua National Corporation’s application to offer its Cash Guarantee Mortgage Program.

Eleventh Circuit determines Chase not liable in Fair Credit Reporting Act lawsuit

ABA files amicus brief urging Third Circuit to review TransUnion class certification ruling

Uncategorized
June 2, 2026

ABA filed a coalition amicus brief urging the Third Circuit to grant TransUnion LLC’s petition to review a district court decision that certified a class action alleging it violated the FCRA by failing to immediately block allegedly fraudulent...

Second Circuit rules Federal Reserve Act does not require Federal Reserve Banks to grant master account

Second Circuit rules Federal Reserve Act does not require Federal Reserve Banks to grant master account

Uncategorized
June 2, 2026

In a unanimous decision, a Second Circuit panel affirmed that banks do not have a statutory right to Federal Reserve master accounts.

Third Circuit affirms dismissal of BIPA claims against Amazon and Pindrop

Third Circuit affirms dismissal of BIPA claims against Amazon and Pindrop

Uncategorized
June 2, 2026

In a unanimous decision, a Third Circuit panel affirmed dismissal of a class action against Amazon Web Services Inc. and Pindrop Security Inc., holding that Pindrop qualifies as a financial institution exempt from BIPA claims related to biometric...

NEWSBYTES

ABA seeks further revisions to draft W-9 tax form

June 9, 2026

ABA, associations: Appeals court should uphold Fed’s Reg II interchange fee standard

June 9, 2026

ABA to FCC: Restrict number resale and number ‘cycling’

June 9, 2026

SPONSORED CONTENT

Your Floorplan Audit and Your Credit Decision Are Weeks Apart. That Gap Has a Price.

Your Floorplan Audit and Your Credit Decision Are Weeks Apart. That Gap Has a Price.

June 1, 2026
A Modern Blueprint for Serving High-Net-Worth Families

A Modern Blueprint for Serving High-Net-Worth Families

May 28, 2026
Why Your Systems Keep Slowing Down — and What to Do About It

AI Is in Your Bank. Is Your Cloud Contract Governing It?

May 20, 2026
Credit Memos at the Convergence Point

Credit Memos at the Convergence Point

May 1, 2026

PODCASTS

Podcast: Creating a feeling of welcome, for customers and new bankers

May 28, 2026

Podcast: How consumer deposits drive full relationship banking

May 14, 2026

Podcast: How an Ohio banker talks with policymakers about stablecoin issues

May 6, 2026

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2026 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2026 American Bankers Association. All rights reserved.