Regulatory Alerts2026-02-26
Proposal of Special Measure Regarding MBaer Merchant Bank AG as a Financial Institution Operating Outside of the United States of Primary Money Laundering Concern
The Financial Crimes Enforcement Network proposes to designate Switzerland-based MBaer Merchant Bank AG as a financial institution of primary money laundering concern under Section 311 of the USA PATRIOT Act. This designation stems from findings that the bank facilitated money laundering for Venezuelan corruption schemes and illicit Russian and Iranian activities while maintaining inadequate anti-money laundering controls. The proposed rule would prohibit U.S. financial institutions from opening or maintaining correspondent accounts for MBaer and require enhanced due diligence for transactions involving the bank.
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