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Aleo International, Ltd. v. Citibank

Supreme Court of New York County

160 Misc.2d 950 (1994)

Relevant factsFree

Aleo (plaintiff) instructed Citibank (defendant) to wire $284,563 to a beneficiary's account at Dresdner Bank in Germany; Dresdner credited the beneficiary's account at a time equivalent to 3:59 a.m. New York time, but Aleo's employee didn't request cancellation until 9:00 a.m. New York time that same day, hours after the funds had already been credited.

IssueFree

Whether, under UCC Article 4A, a cancellation of a payment order is effective only if received at a time allowing the receiving bank a reasonable opportunity to act before the bank accepts the order.

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