Wire Transfer Fraud Liability 2026: Accountholder Recovery, the Bank’s Safe Harbor, and the EFTA–Article 4A Boundary Fight

John E. Lande, Shareholder | Dickinson, Bradshaw, Fowler & Hagen, P.C

John Lande counsels banks on check and wire fraud, cybersecurity, internal and criminal investigations, insider transactions, collections, examinations, and enforcement actions, and helps institutions build practices designed to keep those problems out of litigation. His client base centers on financial institutions, alongside privately held businesses and municipal utilities, and he chairs the Cybersecurity, Data Breach, & Privacy practice group at Dickinson Bradshaw. His courtroom work spans Iowa district court, federal court, and appeals before the Iowa Court of Appeals, the Iowa Supreme Court, and the Eighth Circuit, with regulatory appearances before the Iowa Division of Banking, the FDIC, and the Federal Reserve in Iowa and Washington, D.C.

• Education & Credentials

John earned his J.D. from the University of Iowa College of Law with distinction, receiving the Willard L. Boyd Public Service Distinction, after completing a B.A. cum laude at Drake University. He is admitted to practice in Iowa and before the U.S. Supreme Court, the U.S. Court of Appeals for the Eighth Circuit, and the federal district and bankruptcy courts for both the Northern and Southern Districts of Iowa.

• Recognition & Leadership

Chambers USA has ranked John as a Leading Individual in Litigation: General Commercial Law in Iowa in every edition from 2019 through 2026, after naming him an Up and Coming leader in 2018; its editors note his regular representation of financial institution clients within a broad commercial litigation practice. The Best Lawyers in America has recognized him in Banking and Finance Law (2023–2026 editions), Commercial Litigation and Privacy and Data Security Law (2020–2026 editions), and Construction Law and Litigation – Construction (2026 edition). Earlier honors include the Iowa Defense Counsel Association’s 2014 Rising Star Award and recognition as a Future Leader of the Bar by the Iowa State Bar Association in 2011.

• Professional Involvement

John’s speaking and writing calendar runs heavily to payments fraud and bank liability. He presented “Industrial Fraud System in Asia and U.S. Wire Fraud” at the 2025 Dickinson Bradshaw Banking Law Seminar, taught “Liability for Unauthorized Wire Transfers under the Uniform Commercial Code” as a 2023 Lexology Virtual Masterclass, and covered “Real Time Payments Origination Liability” and “Check Fraud” at the 2024 seminar. His recent writing for the firm’s Iowa Banking Law and Iowa Cybersecurity Law Blogs includes “Wire Fraud in the Age of AI” (2026), “Banks May Be Liable for Fraudulent Consumer Wire Transfers” (2025), and “After a Wire Transfer, That’s Not Your Money Anymore” (2022). He is a member of the Iowa Defense Counsel Association, the American Bar Association’s Tort Trial and Insurance Practice Section, the Iowa State Bar Association, and the Polk County Bar Association.

• Experience

John’s practice has tracked bank fraud liability for more than a decade, from corporate account takeover programs such as “Understanding Liability: Strategies for Avoiding Loss from Corporate Account Takeover” (2014), through wire transfer agreement counseling dating to “Make Sure Your Wire Transfer Agreements Are Wired Properly” (2013), to depositor-liability analysis in “Banks and Depositors Agree to Disagree: Who is Responsible for Unauthorized Wire Transfers?” (2018). His reported matters include In re AgriProcessors, Inc., 859 F.3d 599 (8th Cir. 2017), in which he represented a financial institution on the treatment of loan overdrafts, and First Security Bank & Trust Co. v. Vegt, 511 B.R. 567 (N.D. Iowa 2014), a bank-side federal appeal over a priming lien in a Chapter 12 bankruptcy. He also litigates business torts, contract disputes, agency regulatory actions, and property tax matters across Iowa state and federal courts.

Brennan Eddie, Associate | Dickinson, Bradshaw, Fowler & Hagen, P.C.

Brennan Eddie serves financial institutions in banking law and regulatory compliance, alongside a practice advising individuals, startups, and established businesses on business formation, bankruptcy, corporate governance, corporate reorganization, and contracts and agreements. She also supports organizations and government entities on construction, real estate, and municipal law matters.

• Education & Credentials

Brennan earned her J.D. with high honors from Drake University Law School, where she was a Dwight D. Opperman Scholar and served as Online Editor of the Drake Law Review, following an undergraduate degree in economics from the University of Iowa. She joined the firm after a 2022 summer associateship at Dickinson Bradshaw and is admitted to practice in Iowa.

• Recognition & Leadership

Best Lawyers: Ones to Watch selected Brennan in the areas of Banking and Finance Law and Corporate Law in its 2026 edition, and in Real Estate Law in its 2025 and 2026 editions.

• Professional Involvement

Brennan’s recent speaking work centers on bank liability and payments law. She presented “Presentment Warranty Cases” and “E-sign Acceptability” at the 2025 Dickinson Bradshaw Banking Law Seminar, co-presented “Lending Limits” and sessions on the Iowa Consumer Credit Code and consumer credit collection at the Iowa Bankers Association’s 2025 Lending Law Seminar, and co-presented “Shake-up in Federal Administrative Law” at the 2024 Dickinson Bradshaw Banking Law Seminar. She is a member of the Iowa Bar Association and the Polk County Bar Association.

• Experience

Brennan’s financial institution work spans banking law and regulatory compliance, including presentment warranty case analysis and Iowa Consumer Credit Code counsel, with additional concentrations in cybersecurity and vendor agreements and emerging technology. Her business practice covers formation, governance, reorganization, and contract matters for clients ranging from startups to established companies, and her writing includes analyses of the Iowa Real Estate Transparency Act and real estate practice changes under the proposed NAR settlement.

SESSION 1 – Recovering Fraudulent Wire Transfer Losses: Building the Accountholder’s Case Against the Banks | 12:00pm – 1:00pm

This session examines the accountholder’s litigation toolkit for recovering fraudulent wire transfer losses from originating and beneficiary banks, with emphasis on the EFTA–Article 4A boundary dispute currently before the Second Circuit in New York v. Citibank, N.A. Attorneys will learn how to evaluate and plead EFTA versus UCC Article 4A theories, attack the bank’s commercially reasonable security procedure defense under § 4A-202, and navigate the beneficiary bank privity and knowledge-standard problems crystallized by the Fourth Circuit’s Studco decision. Attendees will leave with a framework for first-72-hour client counseling, claim selection, and discovery targeting in wire fraud recovery matters.

BREAK | 1:00pm – 1:10pm

SESSION 2 – Defending the Safe Harbor: Bank-Side Wire Fraud Liability and the New Nacha Fraud Monitoring Rules | 1:10pm – 2:10pm

This session examines the bank-side defenses to wire fraud liability, focusing on the UCC Article 4A commercially reasonable security procedure safe harbor, the actual-knowledge standard confirmed by the Fourth Circuit in Studco v. 1st Advantage FCU, and the existential threat posed by the EFTA-Article 4A boundary dispute now pending before the Second Circuit in NYAG v. Citibank. Attorneys will analyze how Nacha’s Phase 1 and Phase 2 fraud monitoring rules (effective March and June 2026) create a new compliance floor that functions as litigation evidence of reasonableness or inadequacy. Attendees will leave with a practical framework for advising financial institution clients on safe harbor preservation, compliance posture under the new Nacha rules, and litigation strategy under either outcome in the pending Second Circuit decision.