On Feb. 9, 2018, the Second Circuit decided SPV Osus Ltd. v. UBS AG , affirming the dismissal of UBS AG and related and unrelated foreign financial management companies from litigation brought by alleged victims of the Madoff fraud. Broadly speaking, the complaint alleged that the defendants, with knowledge of Madoff’s illegal activities, kept his Ponzi scheme alive by sponsoring and promoting “feeder funds” based outside the United States that allegedly funneled billions of dollars to Madoff and his company ( Bernard L. Madoff Investment Securities, or BLMIS), resulting in $2.9 billion in damages to the plaintiff, SPV. The defendants, UBS AG (Switzerland) and three of its foreign affiliated banking and financial services companies (collectively, “UBS”), allegedly were responsible for this loss on what was described “in broad strokes” as aiding - and - abetting theories under New York law. As relevant here, the Second Circuit found that the district court lacked personal jurisdiction over the defendants. First, it found this was not an “exceptional case” that warranted deviation from the rule that “general” personal jurisdiction over companies typically exists only where they are incorporated or have their principal place of business. Next, it rejected assertion of “specific” personal jurisdiction because UBS’ contacts with the forum were inadequate and SPV could not link its alleged loss to actions taken by UBS. As discussed further below, these holdings reinforce that foreign banks are justified in relying o n their corporate organizations to provide a measure of protection from U.S. litigation, and that the absence of causation remains a key and broadly applicable ground for finding that specific personal jurisdiction does not exist.