Business email compromise (BEC) and other third-party fraud inducing funds transfers have generated a wave of litigation against banks: not just those where victims hold accounts, but also against the financial institutions where the funds were transferred, even when the victim is not a customer. A threshold question often arises as to whether the beneficiary bank receiving the funds via a wire transfer owes a noncustomer plaintiff any duty of care at all. Most courts uniformly hold that banks owe no duty of care to noncustomers. But in 2024, in Elkin Valley Baptist Church,the United States District Court for the Western District of Pennsylvania went against the weight of authority and answered that question in plaintiffs’ favor.