Following our post on the district court’s extraterritoriality decision, the bankruptcy court dismissed the actions against several defendants on the grounds that the presumption against extraterritoriality and international comity principles limit the scope of § 550(a)(2) such that the trustee of a domestic debtor cannot use it to recover property that the debtor transferred to a foreign entity that subsequently transferred it to another foreign entity. However, on February 25, 2019, the Second Circuit disagreed with the bankruptcy court’s decision and vacated the judgement and remanded the matter back to the bankruptcy court for further proceedings. More to come.