On October 12, 2023, the First Department issued a decision in Chaar v. Arab Bank P.L.C., 2023 NY Slip Op. 05184, holding that there is no quasi in rem jurisdiction when the property upon which jurisdiction would be based is not related to the claims made, explaining:
Quasi in rem jurisdiction requires an analysis of whether the minimum contacts are present. When assessing minimum contacts, the Court must consider the nature and quality of the defendants’ contacts with the State, which must be such as to make it reasonable and just to require the defendant to litigate the claim in the particular forum. Further, when the property serving as the jurisdictional basis [here, the corresponding bank accounts located in New York] have no relationship to the cause of action and there are no other ties among the defendant, the forum and the litigation, quasi-in-rem jurisdiction will be lacking. Plaintiffs claim that defendants took part in real estate acquisitions and made trades on the New York Stock Exchange to provide money transfers and letters of credit; however, none of these activities were connected to plaintiffs’ claims.
(Internal quotations and citations omitted).