FINMA orders MBaer Merchant Bank into liquidation
MBaer must wind down after FINMA found systematic AML and sanctions-control failures
FINMA
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Change
On 27 February 2026, FINMA’s withdrawal of MBaer Merchant Bank AG’s licence and liquidation order became effective after the bank withdrew its appeal.
Why it matters
MBaer can no longer operate as a licensed Swiss bank and must enter liquidation under FINMA-appointed liquidators. FINMA found systematic AML, sanctions-risk and organisational failures, including indications that the bank helped clients circumvent official asset freezes. The case also creates cross-border exposure because FinCEN has proposed Section 311 measures against MBaer as a financial institution of primary money-laundering concern.
Implications
- — FINMA-appointed liquidators must take control of MBaer’s liquidation and wind down the bank under FINMA’s effective order — failure to execute the mandate risks supervisory and legal escalation.
- — MBaer management and operations teams must transfer control of bank records, assets and client-position information to the appointed liquidators — failure to cooperate may obstruct the liquidation process and expose responsible individuals to further action.
- — Banks with correspondent, counterparty or client exposure to MBaer must review relationships in light of FINMA’s liquidation order and FinCEN’s proposed Section 311 measures — failure to reassess exposure may leave unresolved AML, sanctions and correspondent-banking risk.
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