The Financial Crime Enforcement Network (FinCEN) under the US Treasury Department recently designated Swiss bank MBaer Merchant as a "money laundering concern" financial institution under Article 311 of the US Patriot Act.
On February 26, 2026, FinCEN announced a notice proposing a new regulation (NPRM) to identify MBaer as a financial institution with a high risk of money laundering and proposed applying some "special measures" to this bank.
According to FinCEN, MBaer has had many violations of compliance since its establishment in 2018. Initially, the bank was accused of facilitating corruption and money laundering activities related to Venezuela, then expanded to Iran-related money laundering transactions and terrorist financing.
FinCEN's announcement also said that MBaer maintains and seeks to hide many customers, including those on the US, European Union and Swiss economic sanctions lists.
This bank is also accused of facilitating payments related to the Iranian Islamic Revolutionary Guard Corps (IRGC) and the IRGC's Quds forces. Both organizations are on the US sanctions list under anti-terrorism regulations. According to allegations, MBaer has supported more than 50 million USD related to Iranian oil smuggling routes.
Just one day after FinCEN's announcement, the Swiss financial supervisory authority FINMA also issued a strong decision: Revoking MBaer's operating license and proceeding to close the bank.
The move was made after a law enforcement investigation concluded that the bank had "serious and systematic shortcomings" in its anti-money laundering (AML) program and complied with sanctions.
This is the result of an investigation that began in 2024, which found that 80% of the bank's business relationships belonged to the high-risk group, and 98% of the assets the bank received came from high-risk customers.
FINMA said that MBaer repeatedly ignored the internal compliance department, did not conduct a full customer appraisal and still carried out transactions for the sanctioned subjects. The agency called the case "particularly serious" and has opened investigation procedures against 4 related individuals.
The almost simultaneous announcement of FinCEN and FINMA shows the importance of strict customer appraisal and compliance with international financial regulations for financial institutions outside the United States.
The moves against MBaer show that financial regulators are still using long-standing legal tools to tighten compliance with anti-money laundering. This case shows that Washington can closely coordinate with foreign regulators when management interests coincide. The allegations against MBaer have actually lasted for nearly 8 years since the bank was established and FinCEN has long had the right to use Article 311 of the Patriot Act to act if necessary.
Legal experts believe that the MBaer sanctions are seen as a reminder that non-US financial institutions need to pay special attention to Washington's management requirements if they want to maintain access to the US financial system. In the context that the USD still plays a central role in the global payment system, being cut off from the US financial system could seriously affect a bank's international operations.
