Bank of America v. Arnell [1999] Lloyd's L.R. Bank. 399, an application for summary judgment heard before Aikens J., illustrates some of the obstacles that a bank must surmount to recover money paid out on a forged cheque purportedly drawn on its customer's account. First, it must show a sufficient interest in the money to entitle it to sue. Secondly, if the payee of the cheque has passed the proceeds to another person, the bank must trace the money to prove that the defendant received it. Thirdly, the bank will typically have to prove the recipient's fault in receiving the money.