THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
YOURAS ZIANKOVICH, Plaintiff,
vs.
WISE US INC., a Delaware corporation, Defendant.
Case No.: 4:26-cv-01024
COMPLAINT AND JURY DEMAND
I. INTRODUCTION
1. This action arises from Defendant Wise US Inc.’s wrongful restriction and termination of Plaintiff’s account, carried out without adequate notice, without a lawful factual basis, and under the false pretext of sanctions and prohibited activity.
2. Plaintiff is a Texas resident who used his Wise account exclusively for lawful purposes. Defendant nevertheless restricted and closed the account after Plaintiff attempted to make small, lawful humanitarian payments to recipients located in the European Union, despite the absence of any sanctioned jurisdiction, sanctioned person, or illegal transaction.
3. In doing so, Defendant falsely implied that Plaintiff had engaged in sanctions-related or otherwise unlawful conduct, damaging Plaintiff’s reputation, interfering with lawful humanitarian activity, and depriving Plaintiff of contracted financial services without good faith or fair dealing.
4. This case seeks redress for Defendant’s breach of contract, discriminatory and arbitrary conduct, and tortious misconduct, as well as declaratory and injunctive relief to prevent the continued application of such unlawful practices.
5. Defendant’s conduct exemplifies a broader pattern in which private financial institutions substitute ethnic or national identifiers—particularly the word “Belarus”—for individualized legal analysis, thereby penalizing lawful humanitarian activity and persons who have themselves been victims of persecution by the Belarusian regime. This case seeks to halt that practice, particularly where it targets former political prisoners, human rights advocates, and victims of authoritarian regimes.
II. JURISDICTION AND VENUE
6. This Court has subject-matter jurisdiction over this action pursuant to 28 U.S.C. § 1331, because Plaintiff asserts claims arising under the laws of the United States, including claims for discrimination in the making and enforcement of contracts under 42 U.S.C. § 1981.
7. This Court has supplemental jurisdiction over Plaintiff’s state-law claims pursuant to 28 U.S.C. § 1367, as those claims form part of the same case or controversy and arise from a common nucleus of operative facts.
8. This Court has personal jurisdiction over Defendant Wise US Inc. because Defendant purposefully availed itself of the privilege of conducting business in the State of Texas by providing money transmission and account services to Plaintiff, a Texas resident, and by maintaining an ongoing contractual and commercial relationship with Plaintiff in Texas.
9. Defendant’s conduct giving rise to this action was expressly aimed at Texas, and Plaintiff suffered economic and reputational harm in Texas as a direct and foreseeable result of Defendant’s actions.
10. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b) because a substantial part of the events or omissions giving rise to the claims occurred in this District, Plaintiff resides in this District, and Defendant transacted business in this District.
11. Venue is further proper because the effects of Defendant’s unlawful conduct were felt primarily in this District, including the termination of Plaintiff’s account, the interruption of lawful financial activity, and the resulting reputational and economic harm.
12. Any purported arbitration provision invoked by Defendant was presented to Plaintiff on a take-it-or-leave-it basis, without meaningful notice or a meaningful opportunity to assent, and with unilateral modification rights reserved to Defendant. Such provisions were procedurally and substantively unconscionable, were not the product of mutual assent, and do not bar this Court’s jurisdiction over Plaintiff’s claims.
III. PARTIES AND STANDING
13. Plaintiff Youras Ziankovich is an individual and a resident of the State of Texas. Plaintiff maintained a personal account with Defendant Wise US Inc. and used that account for lawful personal and humanitarian purposes.
14. Plaintiff is a party to a valid and enforceable contract with Defendant governing the provision of money transmission and account services. Plaintiff fully performed, or was excused from performing, all obligations required under the contract.
15. Plaintiff has suffered concrete, particularized, and actual injuries as a direct and proximate result of Defendant’s conduct, including but not limited to:
- (a) loss of access to contracted financial services;
- (b) interference with lawful humanitarian activity;
- (c) reputational harm arising from false implications of unlawful conduct;
- (d) economic and consequential damages.
16. These injuries are fairly traceable to Defendant’s acts and omissions and are redressable by monetary, declaratory, and injunctive relief.
17. Defendant Wise US Inc. is a corporation organized under the laws of the State of Delaware and authorized to conduct business in the United States, including in the State of Texas. Defendant provides money transmission, account, and payment services to customers nationwide, including Texas residents.
18. At all relevant times, Defendant acted under color of its contractual authority and internal policies to restrict and terminate Plaintiff’s account and to cancel lawful transactions, including transactions directed to recipients located within the European Union.
19. Defendant’s actions constituted adverse treatment of Plaintiff in the making, performance, and enforcement of a contract, and caused Plaintiff direct injury sufficient to confer standing under Article III of the United States Constitution.
IV. FACTUAL BACKGROUND
20. Plaintiff opened and maintained a personal Wise account in good standing with Defendant Wise US Inc. and used the account exclusively for lawful purposes.
21. Plaintiff used the Wise account, among other things, to make lawful humanitarian and charitable payments within the European Union, including to individuals and organizations located in the Republic of Lithuania.
22. All disputed payments were directed solely to legally existing bank accounts in Lithuania, and all recipients were residents or legal entities of Lithuania, including a duly registered Lithuanian charitable organization, Association Political Prisoners of Belarus.
23. At no point did Defendant acknowledge the humanitarian and anti-regime nature of Plaintiff’s activity or the fact that the organization referenced by name exists specifically to assist victims of political repression in Belarus. Instead, Defendant treated the word “Belarus” itself as an adverse risk indicator.
24. Defendant likewise failed to distinguish between support for victims of political repression and any conduct associated with the Belarusian state, effectively and arbitrarily collapsing those distinct categories into a single adverse risk classification.
25. No funds were sent to Belarus, directly or indirectly, and no transaction involved a sanctioned jurisdiction, sanctioned person, or prohibited activity under United States law or law of the European Union or the United Kingdom.
26. For an extended period of time, Defendant processed Plaintiff’s transactions without incident, objection, or restriction, thereby confirming a course of dealing consistent with the lawful nature of Plaintiff’s account activity.
27. In October 2025, Plaintiff attempted to make small humanitarian payments to the Lithuanian charitable organization Association Political Prisoners of Belarus. These payments were cancelled by Defendant despite their lawful nature and despite the absence of any sanctions-related nexus.
28. Defendant thereafter restricted Plaintiff’s account, preventing Plaintiff from sending or receiving funds and from using associated services, while continuing to display account functionality in a manner that failed to provide clear or effective notice of imminent closure.
29. Defendant demanded that Plaintiff provide additional information and documentation, which Plaintiff did in good faith, including information confirming that the recipients were located in Lithuania and were not subject to any sanctions.
30. Despite Plaintiff’s cooperation and the absence of any prohibited activity, Defendant maintained and escalated the restrictions, and ultimately terminated Plaintiff’s account.
31. Defendant failed to provide Plaintiff with clear, individualized, and reliably delivered notice of the basis for the account termination or a meaningful opportunity to contest the decision prior to closure.
32. Throughout its communications, Defendant invoked sanctions and prohibited activity as a justification for its actions, while failing to identify any specific law, regulation, sanctioned person, or prohibited transaction applicable to Plaintiff’s account activity.
33. Defendant’s communications and public-facing explanations falsely implied that Plaintiff had engaged in sanctions-related or otherwise unlawful conduct, despite Defendant’s knowledge that all transactions were lawful and EU-based.
34. As a result of Defendant’s actions, Plaintiff suffered loss of access to contracted financial services, interference with lawful humanitarian activity, reputational harm, and economic and consequential damages, all of which were foreseeable and proximately caused by Defendant’s conduct.
V. LEGAL CLAIMS
COUNT I
Discrimination in the Making and Enforcement of Contracts
(42 U.S.C. § 1981)
35. Plaintiff realleges and incorporates by reference all preceding paragraphs as if fully set forth herein.
36. Plaintiff is of Belarusian et.hnic and national origin. At all relevant times, Defendant knew, perceived, or reasonably inferred Plaintiff’s ethnic and associational connection to Belarus based on Plaintiff’s identity, communications, and humanitarian activities.
37. Plaintiff entered into and maintained a valid contractual relationship with Defendant for the provision of money transmission and account services. Plaintiff was entitled to make, perform, modify, and enforce that contract on equal terms and free from discrimination.
38. Plaintiff used his Wise account exclusively for lawful transactions, including humanitarian and charitable payments within the European Union. All disputed payments were directed solely to legally existing bank accounts in the Republic of Lithuania, and all recipients were Lithuanian residents or legal entities, including a duly registered Lithuanian charitable organization named Association Political Prisoners of Belarus.
39. Defendant perceived and classified both Plaintiff and the recipients of Plaintiff’s lawful transactions based on ethnic and national origin, including through the presence of the word “Belarus” in the name of the Lithuanian charitable organization, notwithstanding that the organization was lawfully registered in Lithuania, operated within the European Union, and maintained Lithuanian bank accounts.
40. Defendant did not identify any sanctioned jurisdiction, sanctioned person, or prohibited transaction applicable to Plaintiff’s account activity. Instead, Defendant relied on ethnic and national associations linked to Belarus, and on the word “Belarus” itself, as a proxy for illegality, risk, or disfavored status.
41. Based on that perception and classification, Defendant intentionally restricted and terminated Plaintiff’s account and cancelled lawful transactions, thereby interfering with Plaintiff’s right to make, perform, and enforce a contract, even though Plaintiff was in compliance with the contract and applicable law.
42. Defendant’s adverse actions were not based on any neutral, individualized, or uniformly applied compliance criterion, but on Defendant’s perception of Plaintiff’s ethnic origin and associations, and on Defendant’s discriminatory use of ethnic and national identifiers in enforcing its contract.
43. Defendant selectively enforced its policies against Plaintiff, because of perceived ethnic and national associations linked to Belarus, and Plaintiff would not have been subjected to account restriction or termination absent that perception.
44. Absent Defendant’s reliance on Plaintiff’s perceived ethnic and associational connection to Belarus, including the use of the word “Belarus” as a proxy for risk or illegality, Plaintiff’s account would not have been restricted or terminated.
45. Defendant’s discriminatory conduct would not have occurred but for Defendant’s perception of Plaintiff’s ethnic and associational connection to Belarus.
46. Defendant’s conduct constituted intentional discrimination in the making, performance, and enforcement of a contract, in violation of 42 U.S.C. § 1981.
47. As a direct and proximate result of Defendant’s discriminatory conduct, Plaintiff suffered loss of contractual benefits, interference with lawful humanitarian activity, reputational harm arising from false implications of wrongdoing, emotional distress, and other compensable damages.
48. Defendant’s actions were willful, knowing, and in reckless disregard of Plaintiff’s federally protected rights, entitling Plaintiff to compensatory and punitive damages, as well as reasonable attorneys’ fees and costs pursuant to 42 U.S.C. § 1988.
COUNT II
Breach of Contract
(Texas Common Law)
49. Plaintiff realleges and incorporates by reference all preceding paragraphs as if fully set forth herein.
SO. Plaintiff and Defendant entered into a valid and enforceable contract governing the provision of money transmission, account, and payment services, including Defendant’s Customer Agreement and incorporated policies.
51. Plaintiff performed all material obligations required under the contract, or was excused from performance, and at all relevant times used his Wise account solely for lawful purposes.
52. The contract imposed on Defendant duties including, but not limited to, the obligation to exercise contractual discretion in good faith, to apply policies consistently and non-arbitrarily, and to provide reasonable and effective notice prior to materially adverse action such as account restriction or termination.
53. Defendant breached the contract by restricting and terminating Plaintiff’s account without providing clear, individualized, and reliably delivered notice, and without affording Plaintiff a meaningful opportunity to understand, cure, or contest the alleged basis for such action.
54. Defendant further breached the contract by demanding Plaintiff’s response through communication channels that Defendant itself designated as non-monitored or no-reply, and then treating the alleged absence of response as a justification for account termination.
55. Defendant’s public-facing policies and Help Centre representations state that customers are ordinarily provided with advance notice, an explanation of the basis for closure, and an opportunity to move funds or appeal prior to final termination. Defendant failed to follow those procedures with respect to Plaintiff.
56. Defendant also breached the contract by selectively and pretextually enforcing its Acceptable Use Policy, relying on ethnic and national associations linked to the word “Belarus,” rather than on any actual violation of law, sanctions regulation, or contractual term.
57. Defendant’s actions deprived Plain_tiff of the benefit of the bargain, including continued access to contracted financial services, the ability to make lawful humanitarian payments, and the reasonable expectation that contractual discretion would be exercised fairly and in good faith.
58. As a direct and proximate result of Defendant’s breaches, Plaintiff suffered economic damages, consequential damages, loss of contractual benefits, interference with lawful activity, and other damages recoverable under Texas law.
59. Defendant’s breaches were material and excuse any further performance by Plaintiff under the contract.
COUNT III
Defamation and False Light
(Texas Common Law)
60. Plaintiff realleges and incorporates by reference all preceding paragraphs as if fully set forth herein.
61. Defendant, through its written communications to Plaintiff, its customer support responses, and its public-facing explanations regarding account restrictions and closures, made and published statements and implications suggesting that Plaintiff engaged in sanctions-related, prohibited, or otherwise unlawful activity.
62. Defendant’s statements and implications included, but were not limited to, references to sanctions concerns, prohibited activity, withholding or misrepresentation of information, and compliance violations, without identifying any specific illegal act, sanctioned person, or prohibited transaction attributable to Plaintiff.
63. These statements and implications were false and misleading. As alleged herein, all of Plaintiff’s transactions were lawful, directed exclusively to recipients in the European Union, and involved no sanctioned jurisdiction, sanctioned person, or illegal activity.
64. Defendant published such false and misleading statements and implications with knowledge of their falsity or with reckless disregard for their truth, including after Plaintiff provided documentation and explanations confirming the lawful nature of the transactions and the absence of any sanctions nexus.
65. Defendant knew or should have known that its statements and implications would be understood by Plaintiff and by third parties as accusing Plaintiff of unlawful or improper conduct, including sanctions evasion or other financial misconduct.
66. Defendant’s statements and implications were defamatory per se, as they imputed criminal, unethical, or professionally disqualifying conduct to Plaintiff, including conduct incompatible with lawful financial activity and humanitarian engagement.
67. In the alternative, Defendant’s statements and implications placed Plaintiff in a false light that would be highly offensive to a reasonable person, by portraying Plaintiff as a participant in illegal or sanctionable conduct when no such conduct occurred.
68. Defendant published and republished these false and misleading statements and implications to third parties, or did so in a manner that made dissemination to third parties reasonably foreseeable, including financial institutions, payment processors, compliance personnel, and internal systems accessible beyond Plaintiff alone, thereby satisfying the publication element under Texas law.
69. Plaintiff is an attorney, a human rights advocate, and a person who has been recognized as a wrongfully detained person by the U.S. Government and former political prisoner. Defendant’s false statements and implications were particularly injurious to Plaintiff because they falsely associated Plaintiff with the very regime and unlawful conduct from which Plaintiff had suffered state-sponsored persecution, thereby compounding the reputational harm, emotional distress, and damage to Plaintiff’s professional standing and credibility.
70. Defendant’s conduct was willful, malicious, or undertaken with reckless disregard for Plaintiff’s rights, entitling Plaintiff to general, special, and exemplary damages under Texas law.
71. As a direct and proximate result of Defendant’s defamatory conduct, Plaintiff suffered reputational injury, emotional distress, economic harm, and other damages recoverable at law.
COUNT IV
Declaratory and Injunctive Relief
(28 U.S.C. §§ 2201–2202)
72. Plaintiff realleges and incorporates by reference all preceding paragraphs as if fully set forth herein.
73. An actual and justiciable controversy exists between the parties regarding Defendant’s interpretation and enforcement of its Customer Agreement and internal policies, including Defendant’s use of ethnic and national identifiers—specifically the word “Belarus”—as a proxy for illegality, sanctions risk, or prohibited activity.
74. Defendant has asserted, through its actions and communications, that it may restrict or terminate Plaintiff’s account and cancel lawful transactions based on perceived ethnic or national associations, notwithstanding the absence of any sanctioned jurisdiction, sanctioned person, or prohibited transaction.
75. Defendant’s conduct places Plaintiff at a continuing risk of irreparable harm, including the ongoing denial of contracted financial services, interference with lawful humanitarian activity, and the continuing reputational and professional injury arising from Defendant’s false implications of unlawful conduct.
76. Monetary damages alone are insufficient to remedy Defendant’s conduct, because Defendant’s practices threaten continuing and future harm to Plaintiff and to others similarly situated, and because Defendant’s policies, as applied, chill lawful humanitarian and charitable activity.
77. Plaintiff seeks a declaration that Defendant’s use of ethnic or national origin, perceived association with Belarus, or the presence of the word “Belarus” in the name of a lawful European Union-based organization as a basis for adverse contractual action violates federal law and Defendant’s contractual obligations.
78. Plaintiff further seeks injunctive relief prohibiting Defendant from restricting, terminating, or otherwise penalizing Plaintiff’s account activity on the basis of ethnic or national origin, perceived association, or name-based proxies unrelated to any actual violation of law or sanctions regulations.
79. Plaintiff also seeks injunctive relief requiring Defendant to apply its policies in a neutral, individualized, and non-discriminatory manner, and to refrain from making or publishing false or misleading statements or implications suggesting unlawful conduct where no such conduct exists.
80. Plaintiff further seeks injunctive relief prohibiting Defendant from treating humanitarian, human rights, or anti-authoritarian activity connected by name or association to Belarus as presumptively unlawful or sanctionable in the absence of an actual applicable legal prohibition.
81. The declaratory and injunctive relief requested herein is necessary and appropriate to clarify the legal rights and obligations of the parties and to prevent ongoing and future violations of Plaintiff’s federally protected rights.
82. Absent injunctive relief, Defendant’s practices risk normalizing the treatment of ethnic identity, political persecution, and humanitarian advocacy as compliance risk factors, contrary to federal law and fundamental principles of equal contractual access.
VI. PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in his favor and against Defendant, and grant the following relief;
A. Declaratory Relief
A declaration that Defendant’s conduct, as alleged herein, violated 42 U.S.C. § 1981, Texas common law, and Defendant’s contractual obligations, including Defendant’s discriminatory and pretextual use of ethnic or national origin, perceived association, and name-based proxies as a basis for adverse contractual action.
B. Injunctive Relief
Preliminary and permanent injunctive relief prohibiting Defendant from restricting, terminating, or otherwise penalizing Plaintiff’s account activity in the absence of an actual legal prohibition and based on protected characteristics, including but not limited to ethnic or national origin, perceived association, or name-based proxies:
- restricting, terminating, or otherwise penalizing Plaintiff’s account activity on the basis of protected characteristics, including ethnic or national origin, perceived association, or name-based proxies;
- enforcing its policies in a discriminatory, arbitrary, or pretextual manner unrelated to any actual violation of law or sanctions regulations; and
- making or publishing false or misleading statements or implications, suggesting unlawful conduct by Plaintiff where no such conduct exists.
C. Compensatory Damages
An award of compensatory damages in an amount to be determined at trial, including damages for economic loss, loss of contractual benefits, interference with lawful humanitarian activity, emotional distress, and reputational harm.
D. Punitive/ Exemplary Damages
An award of punitive or exemplary damages sufficient to punish Defendant for its willful and reckless misconduct, as pe.rmitted by applicable federal and Texas law, particularly where such conduct targets former political prisoners, human rights advocates, or victims of authoritarian regimes.
E. Separate Findings Regarding Willfulness and Malice
Separate findings that Defendant’s conduct was willful, malicious, or undertaken in reckless disregard of Plaintiff’s federaliy protected rights.
F. Attorneys’ Fees and Costs
An award of reasonable attorneys’ fees, costs, and expenses pursuant to 42 U.S.C. §§ 1988, 28 U.S.C. § 1920, and any other applicable provision of law.
G. Pre- and Post-Judgment Interest
An award of pre-judgment and post-judgment interest as allowed by law-.
H. Such Other and Further Relief
Such other and further legal or equitable relief as the Court deems just and proper.
Dated at Baytown, Texas this 6th day of February 2026.
Respectfully submitted,
Youras Ziankovich, Esq.
Plaintiff Pro Se
601 W Baker Rd., Unit 11
Baytown, TX 77522