On July 7th, the Second Circuit dismissed Racketeer Influenced and Corrupt Practices Act ("RICO") claims asserted by victims of Bernie Madoff's Ponzi scheme against the banks through which Madoff allegedly conducted his fraud. The RICO Amendment to the Private Securities Litigation Reform Act precludes plaintiff's claim. That amendment bars a civil RICO claim premised on predicate acts of securities fraud, including mail or wire fraud, even where the plaintiff could not bring a private securities fraud aiding and abetting claim against the same defendants. MLSMK Investment Co. v. JP Morgan Chase & Co. Reuters noted that a similar case has been filed in bankruptcy court by the trustee for the Securities Investor Protection Corporation against the same banks. SIPC Trustee.