On March 28, 2019, the United States District Court for the Southern District of New York awarded summary judgment to JPMorgan Chase Bank, N.A. on claims brought by TMT Co. Limited (TMT), a global shipping company.  TMT alleged that over $11 million in transfers were made improperly from its bank account in London at the Royal Bank of Scotland, plc (RBS) into an account that RBS held at JPMorgan in New York.  In granting JPMorgan’s summary judgment motion, the Court held that the case should be dismissed because RBS as the account owner was a necessary party that could not be joined to the action.  Satterlee Partners James Coster and Charles Keeley represented JPMorgan in the case.