What does FinCEN’s proposal mean for MBaer Bank clients?

It signals possible limits on U.S. dollar services if finalized. Clients may see slower transfers, more document checks, and higher fees. We suggest confirming correspondent arrangements, arranging backup USD channels, and keeping KYC, tax, and ownership documents updated to avoid delays if counterparties tighten controls.

Is MBaer Bank already cut off from the U.S. financial system?

No. The move is a proposal, not a final rule. However, banks sometimes act early to reduce risk. Clients should monitor official updates, maintain liquidity buffers in CHF, and discuss contingency plans for USD payments and custody with relationship managers in case policies change.

Could this affect other Swiss private banks?

Yes. Even banks without direct exposure to MBaer Bank may tighten onboarding and increase AML checks. Expect more questions on source of wealth, beneficial ownership, and payment purpose. Some products with complex flows may face added reviews, which can extend timelines and raise compliance costs.

What should investors in Switzerland watch next week?

Follow statements from U.S.–Swiss meetings on illicit finance, any Swiss regulator guidance, and changes to correspondent services. Also watch client communications from wealth managers about USD settlement and custody. These signals help gauge whether the FinCEN action could broaden into stricter Swiss banking AML expectations.

Global Market Insights

MBaer Bank February 28: FinCEN Cut-Off Threat; US-Swiss AML Talks Loom

ByHuzaifa Zahoor February 28, 2026February 28, 2026

MBaer Bank faces a high-stakes test after a proposed FinCEN action signaled a potential cut-off from the U.S. financial system. For Swiss clients and investors, the issue is bigger than one firm. It points to tighter Swiss banking AML expectations and higher counterparty risk. With a senior U.S. Treasury official set to meet Swiss regulators next week, we break down what the proposal means, who could be affected, and the practical steps to protect cash flows, portfolios, and relationships.