JPMorgan Did Not 'Aid and Abet' Amaranth’s Manipulation

In evaluating claims against J.P. Morgan in its role as Amaranth Advisors LLC's ("Amaranth") futures commission merchant ("FCM") and clearing broker, the Second Circuit followed Learned Hand's 1938 articulation "that aiding and abetting requires the defendant to 'in some sort associate himself with the venture, that he participate in it as in something that he wishes to bring about, that he seek by his action to make it succeed.'"