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Banking Law Keyed to Malloy, 4th Ed.
Vishipco Line v. Chase Manhattan Bank
Citation:
660 F.2d 854 (1981)Facts
From 1966 until April 24, 1975, Chase Manhattan Bank operated a branch office in Saigon, South Vietnam. Among its depositors were ten Vietnamese corporations primarily engaged in providing shipping services to the U.S. Government in Southeast Asia, and Nguyen Thi Cham, who owned a 200 million piastre certificate of deposit issued by the branch. On April 24, 1975, Chase officials in New York determined that Saigon would soon fall to Communist forces and ordered the branch closed without prior notice to depositors. Local Chase officials balanced the books, shut the vaults, and delivered keys and financial records to personnel at the French Embassy. Saigon fell on April 30, and on May 1, the new government issued a communique stating it was confiscating all establishments including banks. Tran Dinh Truong, a major shareholder of most of the corporate plaintiffs, and Nguyen Thi Cham fled Vietnam before the Communist takeover. After arriving in the United States, they demanded that Chase repay their deposits, but Chase refused. The plaintiffs then brought this action against Chase for breach of contract, seeking recovery of the dollar value of their deposits.
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