On January 25th, the Fifth Circuit reversed, in part, the dismissal of lawsuits filed by the receivers of looted insurance companies against a broker-dealer through which the looted proceeds were laundered. The Court held that the broker-dealer owed a state law duty of care to the insurance companies as sub-account holders of the broker-dealer. Because the sub-accounts used the individual insurance companies' tax ID numbers and addresses, they were identifiable customers of the broker-dealer. As such, the broker-dealer had a limited duty to ensure that the transactions it processed on their behalf, as its customers, were authorized. Chaney v. Dreyfus Service Corp.