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Note, Throwing A Monkey Wrench Into The Wheels Of International Finance: Wells Fargo Asia Ltd. V. Citibank, N.A., Edmund W. Sim

Michigan Journal of International Law

This note attempts to illustrate concisely the issues and potential ramifications of Wells Fargo. After describing the complex factual and procedural histories of the case, the note briefly surveys the various approaches to the Act of State doctrine and suggests that the Court should consider Act of State issues in Wells Fargo. Next, it examines the lower courts' analyses of the case and what effects their rulings would have if the Court were to adopt them. Due to the resulting legal confusion that the lower courts' decisions would wreak on the Eurodollar community, Wells Fargo should not remain …