[DO NOT PUBLISH]
 
IN THE UNITED STATES COURT OF APPEALS
    FOR THE ELEVENTH CIRCUIT
 
       No. 96-5423
 
D.C. Docket No. 96-1971-CIV-KING
 
CARLOS VILLALBA, M.D., Dr., MARIA
DEL CARMEN MIRANDA DE VILLALBA,
ANGELES HIDALGO DE MIRANDA,
MENCHU S.A.,
 
Plaintiffs-Appellants,
 
versus
 
COUTTS S & CO. (USA) INTERNATIONAL,
INTERNATIONAL BANK OF MIAMI,
NATIONSBANK OF FLORIDA,
 
Defendants-Appellees.
 
Appeal from the United States District Court
for the Southern District of Florida
 
(August 14, 1998)
 
 
Before EDMONDSON, Circuit Judge, CLARK and WELLFORD, Senior Circuit Judges.Honorable Harry W. Wellford, Senior U. S. Circuit Judge for the Sixth Circuit Court of Appeals, sitting by designation.
 
WELLFORD, Senior Circuit Judge:
 
   On May 6, 1996, the United States Attorney’s office from the Eastern District of New
  York filed a verified complaint in rem in the United States District Court for the Eastern
  District of New York (Civil Action Case No. CV-96-2241) against $199,710.00 in United
  States currency allegedly obtained from illegal money laundering. On the same day, after a
  review of the complaint, Judge David G. Trager  issued a civil arrest warrant for certain funds
  on deposit, or which were attempted to be deposited on or before May 14, 1996, in certain
  accounts at the three defendant institutions, Coutts&  Co. (USA) Int’l ("Coutts"), International
  Bank of Miami ("Miami Bank"), and NationsBank of Florida ("NationsBank") (collectively,
  "the banks").
 
   Upon the execution of the warrants, the banks allegedly disclosed to the government
  agents information regarding the accounts of the persons or entities listed in "Schedule A"
  attached to the verified complaint, which included specifically plaintiff Maria Del Carmen
  Miranda De Villalba ("Maria")"and all related individuals and entities." Though not specifically
  listed in Schedule A, the accounts of plaintiffs Carlos Villalba, M.D. ("Carlos"), who is Maria
  s husband, Angeles Hidalgo De Villalba("Angeles"), who is Maria’s mother, and Menchu, S.A.
  ("Menchu"), a company in which Maria holds an interest, were also seized.   Allegedly, based
  on the warrant and the verbal instructions of the government agents, the banks disclosed
  in-transit communications and stored electronic information, and also froze accounts held in
  electronic storage. Interestingly, none of the plaintiffs were referred to in the body of the
  verified complaint.
 
   On May 23, 1996, based on the information obtained from the execution of the May 6
  warrant, the United States issued an amended complaint, wherein only three (3) of the 53
  allegations named Maria as having received tainted funds. None of the other plaintiffs were
  mentioned. On June 21, 1996, the New York court issued a judicial subpoena in the in rem
  action, directing that defendant banks produce"(a]ll documents concerning, referring, or
  relating to" Maria, including deposits and withdrawals, opening of accounts information, and
  wire transfer advices and instructions. Details about the accounts of the plaintiffs were revealed
  as a result of that subpoena.
 
   On July 19, 1996, the plaintiffs below filed this action against the banks for damages,
  actual and punitive, claiming that the banks had willfully violated the provisions of the
  Electronic Communications Privacy Act of 1986 ("ECPA"), 18 U.S.C. § 2501, et seq., and §
  2701 et seq., the Right to Financial Privacy Act of 1978 ("RFPA"), 12 U.S.C. § 3401, et seq.,
  Federal Reserve Board Regulation 1(12C.F.R. § 210, et seq.), and Florida statutory law, by
  disclosing the information in their accounts based only on verbal orders of government officials and the general in rem May 6 warrant. In August of 1996,the defendant banks moved to dismiss the complaint on its face pursuant to FED. R. Civ. P. 12(b)(6).The district court found that the plaintiffs failed to state a valid cause of action because the applicable statutes provided "a complete defense" to the plaintiffs’  allegations in light of the fact that the banks had relied on the May 6 warrant when they made the allegedly unlawful disclosures. The plaintiffs now appeal from that ruling.
 
  Standard of Review
 
   We review a district court s Rule 12(b)(6) dismissal de novo, accepting all of the allegations of the complaint as true and construing the allegations in a light most favorable to the plaintiffs. Lopez v. First Union National Bank of Florida, 129 F.3d 1186, 1189 (11th Cir. 1997).  A complaint may not be dismissed for failure to state a claim "unless it appears beyond doubt that the plaintiff can prove no set of facts in support of his claim which would entitle him to relief." Id. (quotations omitted). The issue is not whether the plaintiff will ultimately prevail, but "whether the claimant[s are] entitled to offer evidence to support the[ir] claims. Scheuer v. Rhodes, 416 U.S. 232, 236 (1974).
 
   Claims Under the RFPA, 12 U.S.C. § 3401, et seq.
 
   The plaintiffs claim that the banks violated their privacy rights guaranteed in the RFPA. Before the enactment of the RFPA, the Supreme Court had held that individuals have no Fourth Amendment expectation of privacy in their financial records while those records are in the hands of financial institutions. United States v. Miller, 425 U.S. 435, 443 (1976). The Miller decision prompted Congress to promulgate the RFPA in order to give individuals some privacy rights in their financial records. Section 3403 defines the conditions in which financial institutions may disclose an individual’s financial records and clearly states that "[n]o financial institution... may provide to any Government authority access to or copies of, or the information contained in, the financial records of any customer except in accordance with the provisions of this chapter." Section 3402 defines the conditions in which government officials may access an individual s financial records.
 
   The district court first dismissed the plaintiffs’  claims under the RFPA pursuant to 12U.S.C. § 3413(e), which provides that "[n]othing in this chapter shall apply when financial records are sought by a Government authority under the Federal Rules of Civil or Criminal Procedure or comparable rules in other courts in connection with litigation to which the Government authority and the customer are parties." The court referred to the in rem complaint and accompanying warrant signed by Judge Trager, implying that the defendant banks were required by the warrant to turn over information regarding the accounts of Maria and those accounts "related to" her. On appeal, the plaintiffs argue that exception in §3413 does not apply, and that their complaint is facially valid because it alleges that the government did not satisfy the requirements of 12 U.S.C. § 3402
 
   The exception in § 3413(e) states that the requirements of the chapter will not apply when the financial records sought by the government are pursued "in connection with litigation to which the Government authority and the customer are parties." The plaintiffs herein argue that this provision does not apply in this case because they were not parties to any litigation with the government at the time the warrant in rem was issued. The banks, however, counter that the language in the caption to the verified complaint referred to the individuals listed on Schedule B, including Maria and "all related individuals." Therefore, the banks claim, the plaintiffs were parties in litigation with the government for purposes of applying the exception in § 3413(e).
 
   We cannot agree with the banks and the district court that section 3413(e) protects the banks from liability under the RFPA. By definition, the complaint in rem was brought against none of the plaintiffs herein, but only seeks a remedy against the illegal funds in which the plaintiffs hold an interest. Because the plaintiffs were not parties to the litigation in which the financial records were sought by the government, it was error for the district court to rely on the § 3413(e) exception in dismissing the plaintiffs’  RFPA claim.
 
   In addition, the district court dismissed the plaintiffs’  RFPA claim based on the general proposition that "[n]o cause of action lies under the RFPA where a bank discloses information as required by federal law," citing Velasquez-Campuzano v. Maifa Nat l Bank, Inc., 896 F. Supp. 1415, 1427 (W.D. Tex.1995). When read in the context of the Velasquez-Campuzano decision, the statement is a reference to the specific exception set out in 12 U.S.C. § 3413(d), which provides that nothing in the RFPA"shall authorize the withholding of financial records or information required to be reported in accordance with any Federal statute or rule promulgated thereunder." Id. at 1420. In that case, an officer of the subject bank submitted a Criminal Referral Form to federal authorities inculpating the plaintiffs because he suspected that the plaintiffs had committed a crime. The court held that federal regulations, specifically12 C.F.R. § 27(b)(2), required that the bank file such a form in the face of "known or suspected crimes involving national banks." Id. Consequently, because the bank’s disclosures were made pursuant to federal law, the §3413(d) exception applied, and the plaintiffs could not recover against the bank under the RFPA.
 
   The banks argue that the disclosures in the instant case were made pursuant to a warrant, which was authorized by federal law, and therefore the §3413(d) applies in this case. We do not agree with that logic, where the disclosures were not made pursuant to actual legislation, but merely pursuant to a warrant, the validity of which is challenged in the complaint itself. As explained above, even the authority relied upon by the district court belies the banks contention in this regard. Therefore, we find that because the banks disclosures were not made pursuant to "federal law" as we interpret that term, the exception in §3413(d) does not apply to relieve the banks from potential liability under the RFPA.
 
   We have held that the district court erred in finding that the RFPA is not applicable to the plaintiffs’ claim for relief because of the exceptions in §3413(e) and §3413(d). Under the de novo standard, we must now determine whether the plaintiffs’ complaint states a valid cause of action under the RFPA.
 
   Title 12 U.S.C. §3417(a) provides a remedy for violations of the RFPA:
 
       Any . . . financial institution obtaining or disclosing financial records  or information contained therein in violation of this chapter is liable to the customer to whom such records relate in an amount equal to the sum of –

       (1)  $100 without regard to the volume of records involved;

       (2)  any actual damages sustained by the customer as a result of the  disclosure;

       (3) such punitive damages as the court may allow, where the violation is found to have been willful or intentional; and

       (4) in the case of any successful action to enforce liability under this section, the costs of the action together with reasonable attorney’s fees as determined by the court.

As stated above, §3402 defines the conditions in which government officials may access an individual s records. That section provides:

       Except as provided by section 3403(c) or (d), 3413, or 3414 of this title, no Government authority may have access to or obtain copies of, or the information contained in the financial records of any customer from a financial institution unless the financial records are reasonably described and

       (1) such customer has authorized the disclosure in accordance with section 3404 of this title;

       (2) such financial records are disclosed in response to an administrative subpena [sic] or summons which meets the requirements of section 3405 of this title;

       (3)  such financial records are disclosed in response to a search warrant which meets the requirements of section 3406 of this title;

       (4) such financial records are disclosed in response to a judicial subpena [sic] which meets the requirements of section 3407 of this title; or

       (5) such financial records are disclosed in response to a formal written request which meets the requirements of section 3408 of this title.

 The banks claim that their disclosures were authorized because the government may, under § 3402, have access to financial records if the records are "reasonably described and.., are disclosed in response to a search warrant." The plaintiffs, however, do not claim that the banks are liable for complying with the May 6 warrant to the extent that they allowed the funds in Maria s account to be seized. They concede that the banks "had no alternative but to obey (the terms of the warrant]" with respect to surrendering the funds in her account.  The plaintiffs’ claim, however, that the banks  actions were not protected because (1) the banks divulged financial information about Maria’s account that was not specified in the warrant, (2) the banks seized and divulged information about the other three plaintiffs who were not mentioned in the warrant and whose accounts were claimed not to be "related" within the meaning of the warrant, and (3) the plaintiffs were not given the requisite notice when the warrant was executed.

 The warrant reflects that the court commanded the banks to "arrest, attach and seize the Property until further order of the Court." It did not mention the seizure of other financial records or information. The complaint also alleges that the banks disclosed information, at least in part, due to the verbal instructions of the federal agents. It appears, therefore, that the complaint alleges facts sufficient to maintain a claim under the RFPA, because the banks allegedly disclosed information about the plaintiffs’  accounts beyond the scope of the warrant and did so without the requisite notice.  The claims with respect to the separate accounts of Carlos, Angeles, and Menchu are even stronger, because those plaintiffs were not mentioned specifically in the warrant.  More facts must be considered in order for the court to determine whether those accounts were sufficiently related to the accounts of Maria in order that their claims may be similarly situated. In any event, at this stage in the proceedings, the plaintiffs’ allegations state a valid cause of action under the RFPA.

 Because we find that the district court erred in its findings with respect to the RFPA, and because the plaintiffs stated a claim for relief under the Act, we REVERSE and REMAND this matter for further proceedings.

Claims Under the ECPA, 18 U.S.C. § 2510, et seq

 The plaintiffs’ claim that the banks violated their rights under the ECPA, a/k/a The Wiretap Act, by violating 18 U.S.C. § 2511 and § 2703. Generally, the ECPA protects against intentional interception of in-transit electronic communications and proscribes against intentional, unauthorized access of stored electronic communications. See § 2511 (in-transit communications),§ 2603 (stored electronic communications);see also United States v. Moriarty, 962 F. Supp. 217, 218 (Mass. 1997).

 The district court found that, while the ECPA may provide for the privacy of the financial information at issue, certain provisions of the statute provide "a complete defense" to the plaintiffs’  claims. Specifically, the court cited the following statute:

         Any attorney for the government... may authorize an application to a     Federal judge of competent jurisdiction for, and such judge may grant,     in conformity with section 2518 of this title, an order authorizing or     approving the interception of electronic communications by an investigative     or law enforcement officer having responsibility for the investigation     of the offense as to which the application is made, when such interception     may provide or has provided evidence of any Federal felony.

18 U.S.C. §2516(3). Also, the court noted, § 2518(3)(a) states that "[upon such application the judge may issue an ex parte order.., if the judge determines. . . there is probable cause for belief that an individual is committing, or has committed, or is about to commit a particular offense enumerated in section 2516 of this chapter.. . ." The district court concluded, without analysis, that the May 6 warrant was sufficient to satisfy the above provisions, thereby giving the banks a defense to the plaintiffs’ allegations. We disagree.

 As an initial matter, the district court failed to distinguish sufficiently between the plaintiffs’ claims under §2511, regarding the in-transit communications, and the claims under §2703, regarding disclosures of electronic communications in storage. The Fifth Circuit explained:

       (T]he substantive and procedural requirements for authorization to intercept  electronic communications are quite different from those for accessing stored electronic communications. For example, a governmental entity may gain access to the contents of electronic communications that have been in electronic storage for less than 180 days by obtaining a warrant.  See 18 U.S.C. § 2703(a). But there are more stringent, complicated requirements for the interception of electronic communications; a court order is required. See 18 U.S.C. § 2518.

       Second, other requirements applicable to the interception of electronic communications . . . are not imposed when the communications at issue are not in the process of being transmitted at the moment of seizure, but instead are in electronic storage.

Steve Jackson Gaines, Inc. v. United States Secret Service, 36 F.3d 457,463 (5th Cir. 1994). In Steve Jackson Games, the court explained that the risk involved in intercepting in-transit communications is greater because law enforcement officers cannot know in advance the contents of in-transit communication, and which, if any, will be relevant to the crime being investigated. Id.

 It seems that the district court construed the warrant issued herein as a "court order" for purposes of § 2516 and § 2518. In finding that the "order" provided a defense to the banks, the district court must have implicitly found that the “order" satisfied the requirements found in §2518 of the ECPA. That section requires, among other things, that orders authorizing the interception of any electronic communication shall specify:

       (a) the identity of the person, if known, whose communications are to be intercepted;

       (b) the nature and location of the communications facilities as to which, or the place where, authority to intercept is granted;

       (c) a particular description of the type of communication sought to be intercepted, and a statement of the particular offense to which it relates;

       (d) the identity of the agency authorized to intercept the communications,     and of the person authorizing the application; and

       (e) the period of time during which such interception is authorized, including a statement as to whether or not the interception shall automatically terminate when the described communication has been first obtained.

18 U.S.C. §2518(4). Other requirements for such an order are imposed under §2518 for the interception of in-transit electronic communications.

 We find that the May 6 warrant issued in this case does not satisfy the "order" requirement of §2516. The district judge made no findings of fact with respect to Maria and the other plaintiffs, particularly in light of the fact that those parties were not mentioned in the body of the in rem complaint as having committed any crime. Furthermore, the in-transit communications sought to be intercepted were not described, nor was a statement made as to the offense to which it relates. The warrant simply commanded the banks to "arrest, attach and seize" the accounts, with no mention of in-transit communications. Therefore, we find that the district court erred in finding that the ECPA provided the banks a complete defense, considering only the face of the pleadings.

 Although §2516 does not provide the defendants a defense to the action, we must review de novo whether the plaintiffs have stated facially valid claim under either §2511 or §2703 of the ECPA. Section 2511(3)(a) provides that "an electronic communication service . . . shall not intentionally divulge the contents of any communication . . . while in transmission on that service to any person or entity other than an addressee or intended recipient of such communication."  According to the letter of the statute, a plaintiff must allege that a communication was intentionally divulged "while in transit." See Lopez v. First Union National Bank of Florida, 129 F.3d 1186, 1190 (11th Cir. 1997). In paragraph 32 of the plaintiffs’ complaint, they specifically allege that the banks violated their rights by "intercepting, disclosing and providing the United States with access to the content of in transit electronic communication information." Furthermore, the plaintiffs allege that such disclosures were made "without 'good faith reliance on the warrant." Thus, the plaintiffs have stated a valid cause of action pursuant to §2511.Id. (plaintiff failed to state a claim under § 2511 because the complaint did not allege that the bank disclosed communication in "transmission").
 With respect to the plaintiffs’ §2703 claim, the applicable statute provides that an entity providing an electronic service to the public, which includes the banks involved herein, "shall not knowingly divulge to any person or entity the contents of a communication while in electronic storage" by that service. 18 U.S.C. § 2702(a)(1). Section 2703 defines the conditions in which an electronic service may disclose electronic communications to the government. Under that section, the government may require the disclosure of communications in electronic storage that have been in electronic storage for 180 days or less, but "only pursuant to a warrant issued under the Federal Rules of Criminal Procedure or equivalent State warrant." 18 U.S.C. § 2703(a).

 The plaintiffs’ complaint alleges in paragraph 34 that the banks "did disclose, to the U.S. Government the contents of electronic fund transfer communication and financial information in electronic storage for less than 180 days." The banks argue that this allegation is insufficient in light of the fact that they disclosed the communication in electronic storage pursuant to the May 6 warrant. The complaint refers to the May 6 warrant, but alleges that the disclosures were made "without 'good faith reliance on a valid warrant." The complaint further alleges that, prior to the execution of the May 6 warrant, the banks disclosed protected information pursuant to a verbal agreement with the government. This court has recently held that, in order to state a prima facie claim under §2703, it is sufficient to allege that the disclosure of information held in electronic storage was made pursuant to "verbal instructions" instead of a warrant. Lopez, 129 F.3d at 1190. Because the complaint in this case makes similar allegations, we find that the plaintiffs have stated a valid claim under §2703.

 In sum, we find that the plaintiffs have stated claims upon which relief may be granted under §2511 and §2703 of the ECPA. But determining whether, and to what extent, the banks can support valid defenses would be premature at this stage, and the district court must make findings of fact and conclusions of law based on the evidence. On remand, the district court may consider other arguments raised by the banks in their appellate briefs, such as their claim that no "interception"of "electronic communications" occurred within the meaning of the ECPA; that the banks relied in"good faith" on the warrant (see § 2520); and that the banks are entitled to the protection of the Safe Harbor defense of 31 U.S.C. § 5813(g)(3).

Claims Under Florida State Law

 The plaintiffs set forth allegations under the Uniform Commercial Code ("U.C.C.") - Fund Transfers, Fla Stats. §670.406, §670.502, and §670.503, claiming that the banks unlawfully "garnished the proceeds of the electronic fund transfer before the serving of any valid in rem warrant." The district court dismissed the claims under the Florida statutes because it found those statutes to be "inapposite to Plaintiffs’ allegations." We are of the view that the only provision arguably applicable in this case is § 670.503.Florida statute 670.503, entitled "Injunction or restraining order with respect to funds transfer,"provides:

       For proper cause and in compliance with applicable law, a court may restrain:

       (1)  A person from issuing a payment order to initiate a funds transfer;

       (2)  An originator s bank from executing the payment order of the  originator;

       (3)  The beneficiary s bank from releasing funds to the beneficiary     or the beneficiary from withdrawing the funds.

       A court may not otherwise restrain a person from issuing a payment order, paying or receiving payment of a payment order, or otherwise acting with respect to a funds transfer.

 On appeal, the plaintiffs argue that the restraint of their funds violated their rights under this statute because it was based upon "deficient legal restraint," i.e., the warrant was deficient in that it did not name the Carlos, Angeles, or Menchu specifically. As such, they argue, the banks were without authority to restrain their funds. It is apparent that Maria has no claim under this section, because she concedes that the funds in her account were seized pursuant to the May 6 warrant which specifically ordered the seizure of funds deposited in accounts bearing her name.

 In our view, the remaining plaintiffs also cannot maintain a private right of action under §670.503.  We agree with the reasoning in Manufacturas Int’l v. Manufactures Hanover Trust Co., 792 F. Supp.180, 194 (N.Y. 1992), which dealt with the New York version of the U.C.C., which is substantially the same as the Code at issue here. In that case, the district court found that banks that restrain funds transfers in federal forfeiture cases pursuant to this statute should not be held liable under the U.C.C. The court stated that "(t]he policies of article 4A are served by protecting the intermediary banks in forfeiture cases. The courts should hesitate to provide restrictions on their own powers to act swiftly."Id. The plaintiffs cite to no authority that would provide them with a basis to maintain a cause of action under this statute. Therefore, we affirm the district court s dismissal of the U.C.C. claims on the face of the complaint.

Conclusion

 In light of the foregoing, we REVERSE the dismissal of the plaintiffs’ claims under the RFPA and the ECPA and REMAND to the district court for further proceedings consistent with this opinion. We AFFIRM the district court insofar as it granted the banks a dismissal of the U.C.C. claims relating to the seizure of funds in accounts in the name of Maria pursuant to warrant, including any joint account bearing her name. We also AFFIRM dismissal of the Florida state law claims with respect to the other three plaintiffs.