Mohammad Farshad Abdollah Nia, an Iranian citizen living in the United States, sued Bank of America after the bank closed his credit card account in 2019 under its Consumer Residency Monitoring policy. The policy requires accountholders who are citizens of comprehensively sanctioned countries like Iran to periodically submit documents proving they are not present or permanently resident in sanctioned countries.

Nia's account was closed after the bank erroneously classified his Form I-797C immigration document as temporary rather than permanent proof of residency, leading to confusion over expiration dates and document requirements. He had maintained his account since 2015, regularly submitting his driver's license as proof of residency.

Nia filed claims under 42 U.S.C. § 1981, the Equal Credit Opportunity Act, the California Unruh Civil Rights Act, and the California Unfair Competition Law. The district court granted summary judgment for the bank on most claims based on IEEPA's liability shield, and Nia voluntarily dismissed his remaining ECOA notice claim and associated UCL claim before appealing.

Writing for a unanimous three-judge panel, Circuit Judge Lawrence VanDyke affirmed the district court's summary judgment for the bank, rejecting Nia's argument that the International Emergency Economic Powers Act's liability shield applies only to actions specifically mandated by sanctions regulations. "Nia's argument has no root in the text of the statute," VanDyke wrote. "Neither term suggests compulsion. And the liability shield extends to actions taken pursuant to and in reliance on 'instruction[s]' or 'direction[s],' neither of which imply compulsion either."

The court held that the bank's policy "falls comfortably within the liability shield's ambit" because it was "clearly built around the demands of the ITSR." VanDyke wrote that "applying a sanctions compliance program based on citizenship may not be compelled by the ITSR, but it is certainly permitted under OFAC's guidelines."

The court also rejected Nia's arguments that the bank acted in bad faith, finding no genuine issue of material fact. VanDyke dismissed Nia's reliance on seven Consumer Financial Protection Bureau complaints as evidence of bad faith, noting that the bank "has served 67,000 Iranian citizen accountholders since 2016."