What is the FinCEN proposal against MBaer bank?

FinCEN proposed a special measure that would prohibit U.S. financial institutions from maintaining correspondent or payable-through accounts for MBaer bank. If adopted, the bank would be cut off from standard USD clearing channels. The proposal follows allegations of illicit flows involving sanctioned connections and signals elevated money laundering risk.

Could MBaer bank still operate if barred from the U.S. system?

Yes, the bank could continue domestic services and certain cross-border activities in CHF or EUR. The major impact would be on USD payments and services that rely on U.S. correspondent accounts. Clients may face rerouting, added costs, and delays. The proposal is not final, and regulatory reviews continue.

How should Swiss SMEs prepare for possible disruption?

Map all USD exposures, including suppliers, payroll, and trade finance. Test alternative payment routes, open backup accounts where prudent, and confirm FX hedging capacity without U.S. rails. Keep KYC files current and request service assurances in writing. Clear documentation helps auditors and reduces operational risk if changes occur.

Does this action affect other Swiss banks?

The proposal targets one bank, but the signal is broader. Counterparties may raise due diligence and enhance sanctions controls across relationships. Some institutions could limit higher-risk business until clarity improves. Expect more screening, more questions, and possible onboarding delays as firms respond to perceived money laundering risk.

Global Market Insights

February 27: FinCEN Seeks to Bar MBaer Bank From US Financial System

ByDanny Kontos February 28, 2026

MBaer bank faces a major test after the U.S. Financial Crimes Enforcement Network (FinCEN) announced a proposal on February 27 to bar the Zurich lender from U.S. correspondent banking. The FinCEN proposal flags alleged illicit flows and raises a money laundering risk warning. If finalized, MBaer bank could lose USD clearing access, disrupting dollar payments for Swiss clients. Swiss regulator FINMA has installed a monitor while the bank appeals. We outline what this means for Swiss customers, counterparties, and compliance planning across CH.