Filed: May 6, 2026
Forum: American Arbitration Association (AAA)
PARTIES
1. Claimant, Youras Ziankovich, is an individual consumer residing in Baytown, Texas, proceeding pro se.
2. Respondent, Wise US Inc., is a financial technology company providing international money transfer services, with its principal place of business in New York, New York.
3. Respondent is represented by Burr & Forman, LLP.
JURISDICTION AND ARBITRATION BASIS
4. This arbitration is initiated pursuant to a federal court order compelling arbitration.
5. Claimant does not concede the existence or enforceability of any arbitration agreement and proceeds under express reservation of rights.
RESERVATION OF RIGHTS
6. Claimant expressly reserves all rights and objections with respect to the existence, validity, and enforceability of any alleged arbitration agreement.
7. Claimant does not concede that a valid and binding arbitration agreement exists and participates in this proceeding solely pursuant to the Court’s order compelling arbitration.
8. Nothing in this submission shall be deemed a waiver of any jurisdictional, contractual, or statutory rights, claims, or defenses.
FACTUAL BACKGROUND
9. This dispute arises from Respondent’s wrongful, arbitrary, and discriminatory restriction and termination of Claimant’s financial account and transactions.
10. Claimant used Respondent’s platform for lawful international financial activity, including humanitarian-related payments.
11. Respondent canceled multiple transactions and imposed restrictions without valid justification.
12. Respondent’s actions were not based on individualized risk assessment, but rather on broad and undisclosed internal policies that use geographic or nationality-based indicators as proxy risk factors.
13. Such policies are applied without transparency, due process, or meaningful opportunity to contest, resulting in arbitrary and discriminatory denial of financial services.
14. Respondent selectively enforced its internal policies using Belarus-related identifiers as a proxy risk factor. This resulted in discriminatory treatment and denial of services to Claimant.
15. Respondent’s actions prevented Claimant from sending and receiving funds and materially interfered with his contractual rights and lawful financial activity.
16. Respondent knew or should have known that its policies and actions would result in unjustified denial of services and harm to Claimant, yet continued such conduct in reckless disregard of Claimant’s rights.
17. Additionally, Respondent’s conduct created false implications that Claimant was engaged in illegal or prohibited activity, causing reputational harm.
18. Respondent failed to provide any meaningful explanation, appeal mechanism, or due process in connection with its actions.
CLAIMS FOR RELIEF
COUNT I – BREACH OF CONTRACT
19. Claimant repeats and realleges paragraphs 1–18 as if fully set forth herein.
20. Respondent entered into a contractual relationship with Claimant by providing financial services.
21. Respondent breached its contractual obligations by arbitrarily restricting and terminating Claimant’s access to its services without valid cause.
22. As a result, Claimant was deprived of the benefits of the agreement.
COUNT II – DISCRIMINATORY DENIAL OF SERVICES
23. Claimant repeats and realleges paragraphs 1–22.
24. Respondent engaged in discriminatory denial of services by applying internal risk controls based on perceived national or ethnic associations rather than individualized conduct.
25. Such actions resulted in unequal access to financial services and unjustified exclusion from Respondent’s platform.
COUNT III – DEFAMATION
26. Claimant repeats and realleges paragraphs 1–25.
27. Respondent made and communicated false and damaging implications that Claimant was engaged in unlawful or prohibited conduct, including through transaction restrictions and account actions that inherently signal wrongdoing.
28. Such statements and implications were false, unsubstantiated, and harmful to Claimant’s reputation.
COUNT IV – BREACH OF IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING
29. Claimant repeats and realleges paragraphs 1–28.
30. Respondent acted in bad faith by arbitrarily restricting Claimant’s account and transactions.
31. Such conduct deprived Claimant of the expected benefits of the contractual relationship.
COUNT V – UNJUST ENRICHMENT
32. Claimant repeats and realleges paragraphs 1–31.
33. Respondent retained the benefits of its relationship with Claimant while denying access to its services.
34. This conduct resulted in inequitable and unjust enrichment.
COUNT VI – ARBITRARY AND CAPRICIOUS CONDUCT
35. Claimant repeats and realleges paragraphs 1–34.
36. Respondent exercised its discretion in an arbitrary and capricious manner by imposing restrictions without clear standards, explanation, or consistency.
37. As a result, Claimant was deprived of fair access to financial services.
DAMAGES
38. Claimant seeks damages in the amount of $350,000, including compensatory and punitive damages, with the final amount to be determined at hearing.
39. Damages further include loss of access to essential financial infrastructure and resulting economic and personal harm.
40. These damages were directly and proximately caused by Respondent’s conduct.
RELIEF REQUESTED
41. Claimant requests monetary damages, declaratory and injunctive relief, punitive damages, and any additional relief deemed appropriate by the arbitrator.