In the case of Citibank, N.A. v. Wells Fargo Asia Ltd., 1989, the U.S Supreme Court was asked to resolve a dispute between two banks over their respective rights and liabilities in relation to a letter of credit transaction involving an Iranian bank that had been affected by sanctions imposed on Iran during the hostage crisis in 1979-1981. The issue at hand was whether or not Citibank could recover from Wells Fargo for payments made under letters of credit issued by Bank Markazi (the Central Bank of Iran) which were confirmed by Wells Fargo but reimbursed through Citibank as per arrangement prior to sanctions. After lower courts ruled in favor of Wells Fargo, stating that government regulations absolved it from liability due to impossibility caused by governmental order, the Supreme Court reversed this decision upon appeal. It held that while such regulations may have prevented performance initially, they did not permanently excuse non-performance once those restrictions were lifted; hence making it possible for obligations under these letters of credit to be fulfilled subsequently.

The dissenting opinion in the CITIBANK, N.A. v. WELLS FARGO ASIA LTD., 1989 case argued that Citibank should not be held liable for Wells Fargo's loss due to a fraudulent telex message instructing them to transfer funds from their account with Citibank. The dissenters believed that the Uniform Commercial Code (UCC) did not apply because it was designed for domestic transactions and this case involved international banking practices which are governed by different rules and customs. They also disagreed with the majority's interpretation of UCC provisions regarding security procedures, arguing that these were intended to protect banks against fraud committed by customers rather than other banks or third parties. Furthermore, they contended that even if UCC applied, Citibank had complied with reasonable commercial standards of fair dealing.