Financial Accounts Abroad May Be Accessed to Satisfy Domestic Judgments

Koehler v. Bank of Bermuda, 12 N.Y.3d 533, 833 N.Y.S.2d 763 (2009), held that courts have authority to order multinational financial institutions to deliver assets of its customers, wherever located throughout the world, into New York to satisfy judgments entered against the institution's customers. The Koehler decision serves as an additional weapon to secure enforcement of judgments that might otherwise go unsatisfied because of difficulty getting foreign courts to recognize and enforce U.S. judgments, especially if obtained by default as was the case here.

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