Holding foreign organizations possess due process rights only if they develop "substantial connections" within the United States (quoting Verdugo-Urquidez , 494 U.S. at 271, 110 S.Ct. 1056 )
In Clifford v. United States, 136 F.3d 144 (D.C. Cir. 1998), during the course of a criminal forfeiture proceeding, the district court appointed a trustee to liquidate the defendant bank's assets.