On September 16th, the Second Circuit affirmed the dismissal of plaintiffs' state law claims against the defendant banks for allegedly aiding and abetting Bernie Madoff's fraud. Plaintiffs invested with various foreign investment vehicles which, in turn, allegedly invested plaintiffs' money with Madoff. The district court dismissed the claims as precluded by the Securities Litigation Uniform Standards Act ("SLUSA"). Affirming, the Second Circuit held that SLUSA precludes plaintiffs' claims against the banks because the claims are predicated on the banks' involvement with Madoff's fraudulent securities transactions. The fact that Madoff may not have actually executed the pretended securities did not take the case outside the ambit of SLUSA. Trezziova v. Kohn.