What exactly did FinCEN propose regarding MBaer?

FinCEN proposed a rule that would bar US banks from keeping correspondent or payable-through accounts for MBaer and require controls to block indirect access. If finalized, MBaer’s direct USD clearing would stop, pushing payments to alternative routes. The proposal responds to alleged illicit flows and moves into a public comment phase.

How could this affect my USD payments from Switzerland?

You may face slower transfers, higher fees, new cut-off times, and tighter due diligence if payments must be rerouted through other banks. Some US institutions may reduce risk by limiting related Swiss relationships. Ask your bank which correspondents are used today, what backups exist, and how service levels will be maintained.

What is Finma’s role while the case is on appeal?

Finma has appointed a monitor at MBaer to oversee controls and reporting while its enforcement case is on appeal. The monitor does not predetermine outcomes. It usually focuses on anti-money laundering processes, sanctions screening, and governance, and can support faster remediation and clearer communication with clients and counterparties.

What should investors and treasurers in Switzerland do now?

Map all USD flows that touch MBaer, verify correspondent banks, and secure backup providers. Update counterparty risk scores and sanctions checks, add substitution clauses to key agreements, and prepare client communications for possible delays. Track FinCEN announcements and Finma updates so decisions on routing, custody, and credit lines can move quickly.

Law and Government

MBaer Bank February 27: FinCEN Seeks to Cut US Access Over AML

ByDanny Kontos February 28, 2026February 28, 2026

FinCEN has proposed denying Zurich-based MBaer Merchant Bank access to the US financial system. The filing cites MBaer bank money laundering risks tied to illicit actors. If adopted, US banks would have to end correspondent accounts with MBaer and block indirect access. Finma has installed a monitor while its enforcement case is on appeal. For Swiss investors and corporates, the FinCEN proposal raises questions on USD payments, funding costs, and counterparty risk. We outline the key facts, timelines, and steps to protect portfolios and cash flows.