In Motorola Credit Corp. v. Standard Chartered Bank, 2014 N.Y. Slip Op. 07199 (N.Y. Oct. 23, 2014), plaintiff Motorola obtained more than $3 billion in judgments against Turkish companies and their principals (the “Uzans”) for fraudulently diverting loan proceeds. After the Uzans refused to pay the judgments, a federal district court in New York froze their assets, entered an order restraining defendant, a foreign bank with a branch in New York, from transferring any of Uzans' deposits, regardless of where the assets were located, which was significant because all of the Uzans’ assets were located in foreign branches. On appeal, the Second Circuit certified the following question to the New York Court of Appeals: whether New York’s “separate entity rule” precludes a court from ordering a garnishee bank operating branches in New York to restrain a debtor's assets held in foreign branches of the bank. The New York Court of Appeals, in a divided opinion, answered the certified question in the affirmative. The court explained that the separate entity rule provides that even when a garnishee bank with a New York branch is subject to personal jurisdiction, its other branches are to be treated as separate entities for purposes of post-judgment proceedings. In other words, a restraining notice or turnover order served on a New York branch will be effective only for assets held in accounts at that branch, and will have no impact on assets in other branches. The court reasoned that the separate entity rule promoted policies of international comity, protected banks from being subject to competing international claims and the possibility of double liability, and would avoid placing an “intolerable burden” on banks of having to ascertain and monitor the status of bank accounts in numerous foreign branches.