Banco San Juan Internacional, Inc. v. The Federal Reserve Bank of New York:Date Argued: January 29th, 2026; Docket Number: 25-1144

Case Summary: Banco San Juan Internacional, Inc. v. The Federal Reserve Bank of New York arises from the Federal Reserve Bank of New York’s termination of Banco San Juan Internacional’s master account at the New York Fed, which the bank claims was unlawful under federal and state law.At the lower court level in the Southern District of New York, Banco San Juan Internacional, a Puerto Rico international banking entity, sued the Federal Reserve Bank of New York and the Board of Governors of the Federal Reserve System after FRBNY closed its master account, arguing that it had a right to such an account under the Federal Reserve Act and that the closure violated the Administrative Procedure Act, the Mandamus Act, the Declaratory Judgment Act, the Fifth Amendment’s Due Process Clause, and New York contract law duties of care and good faith. The district court (Judge John G. Koeltl) first denied Banco San Juan’s motion for a preliminary injunction seeking to force restoration or maintenance of the master account, holding that the Federal Reserve Act does not create a statutory entitlement to a master account and that the Federal Reserve Bank has broad discretionary authority under 12 U.S.C. § 342 to grant, deny, or terminate such accounts. In a later opinion and order, the court dismissed all of the bank’s claims, concluding that the master‑account decision was not reviewable under the APA, that the bank lacked a protected property interest for due process purposes, and that the master account agreement allowed FRBNY to terminate the account, defeating the contract and implied‑covenant claims; the amended complaint was ultimately dismissed with prejudice.Banco San Juan Internacional then appealed that dismissal to the United States Court of Appeals for the Second Circuit, which docketed the case as No. 25‑1144 on May 5, 2025, with Banco San Juan as appellant and the Federal Reserve Bank of New York as appellee. In the present court, the Second Circuit is considering whether the district court erred in treating the Federal Reserve’s master‑account decisions as discretionary and largely unreviewable and in rejecting Banco San Juan’s statutory, constitutional, and contract theories, and the court heard oral argument in the appeal on January 29, 2026, under docket number 25‑1144.