The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) on Feb. 26, 2026 proposed barring MBaer Merchant Bank from accessing the dollar-clearing system, labeling it a "primary money laundering concern." The move triggered immediate fallout: J.P. Morgan suspended correspondent banking services for MBaer, while Zürcher Kantonalbank halted euro transactions. The bank’s entire board resigned within hours of the announcement.
FinCEN’s 15-page Notice of Proposed Rulemaking (NPRM) alleges MBaer acted as a conduit for illicit funds from Venezuela’s PdVSA corruption network, Russian entities linked to sanctioned individuals, and Iranian-related transactions. The accusations hinge on four named individuals, all of whom have denied the claims in public filings. The NPRM cites media reports, blogs and unspecified non-public data, but provides no concrete transaction evidence or named clients tied to the alleged schemes.
The Venezuela allegations center on Alessandro Bazzoni, a former minority shareholder sanctioned by the U.S. Office of Foreign Assets Control (OFAC) in 2021 over his ties to Harvest Natural Resources, a New York-listed oil company with Venezuelan operations. Bazzoni’s OFAC designation was lifted in January 2025. His wife, Siri Evjemo-Nysveen, briefly served on MBaer’s board with Finma approval. The NPRM claims she used her position to facilitate PdVSA-related payments, but offers no transaction details or corroborating evidence beyond unnamed reports.
The Iran and Russia sections of the NPRM rely on classified transaction data reviewed by FinCEN, though the agency couches its assertions in conditional language. For example, it cites a $14.3 million payment to a Russian account associated with sanctioned politician Viktor Medvedchuk as "indicative of" money laundering, without specifying the account holder or transaction date. A separate $10 million transfer to a Russian beneficiary is similarly described as suspicious, but lacks context on ownership or purpose.
MBaer has not been accused of violating Swiss law, and Finma, Switzerland’s financial regulator, cleared the bank in prior reviews. The NPRM allows a 30-day public comment period, during which MBaer may challenge the allegations. Legal experts note that even a proposed rule can devastate a bank’s operations, as correspondent banks and counterparties often sever ties preemptively.
The case has reignited scrutiny of Switzerland’s anti-money laundering controls, particularly regarding high-risk jurisdictions. Between 2015 and 2021, Finma investigated nearly 30 Swiss banks over PdVSA-related funds; five faced enforcement actions. MBaer, founded in 2018, was not among them. The bank’s founders and legal team argue the FinCEN allegations are based on flawed or outdated information, with no verifiable links to illicit activity.
The NPRM’s weakest section is its Venezuela narrative, which relies exclusively on press reports and blogs marked by FinCEN as "reportedly" or "allegedly." None of the four individuals named—Bazzoni, Evjemo-Nysveen, Venezuelan businessman Jose Luis Chavez Calva, or Spanish airline Plus Ultra Líneas Aéreas—have been sanctioned by OFAC in connection with MBaer, and all have denied any wrongdoing in filings with FinCEN.
