MBaer Merchant Bank
Swiss private bank liquidated in 2026
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MBaer Merchant Bank was a Swiss private bank headquartered in Zurich. It operated in the private client and transaction banking segments from 2018 until its liquidation in 2026, following regulatory action by the Swiss Financial Market Supervisory Authority (FINMA) and designation by United States authorities as a primary money laundering concern.
| Company type | Private bank |
|---|---|
| Industry | Banking |
| Founded | 2018 |
| Defunct | 2026 |
| Headquarters | Zurich, Switzerland |
| Services | Private banking, transaction banking |
| Total assets | CHF 4.9 billion (2025) |
Number of employees | 60+ |
Background
FINMA investigation and enforcement proceedings
In 2024, FINMA opened enforcement proceedings against MBaer and appointed an investigating agent, following investigations into client groups with connections to sanctions imposed on Russia or linked to criminal proceedings. The investigation uncovered serious, systemic deficiencies in the bank's compliance with anti-money laundering due diligence obligations, its administrative organization, and its risk management.[1]
Investigators found that 80% of the bank's business relationships carried elevated risks, and that at the time of the investigation, 98% of incoming assets originated from high-risk clients.[2] The bank repeatedly disregarded recommendations from its own compliance department without documented justification, failed to adequately investigate the backgrounds of business relationships and transactions, and in some instances did not fulfil its reporting obligations under anti-money laundering legislation at all, or did so belatedly. In several cases, MBaer executed transactions on behalf of clients who were on sanctions lists or whose assets had been frozen by domestic criminal authorities.[1]
FINMA concluded that the bank had actively assisted clients in circumventing official asset freezes, and that its conduct and inadequate organization had exposed both the bank and the broader Swiss financial sector to disproportionately high risks.[1] The authority determined that the licensing requirements relating to proper business conduct and organisational standards were no longer met, and that the deficiencies were irreparable under the prevailing circumstances.[3]
US designation and liquidation
On 26 February 2026, the Financial Crimes Enforcement Network (FinCEN), part of the United States Department of the Treasury, recommended measures under Section 311 of the USA PATRIOT Act and designated MBaer as a financial institution of primary money laundering concern.[1] US Treasury Secretary Scott Bessent stated that the bank had channelled hundreds of millions of dollars through the US financial system on behalf of actors with ties to Iran and Russia.[3] US authorities alleged that MBaer and its employees facilitated corruption linked to Russian money laundering, as well as terrorist financing on behalf of Iran's Islamic Revolutionary Guard Corps and its Quds Force.[2]
The following day, FINMA revoked MBaer's banking licence and ordered the bank into liquidation. The enforcement proceedings had formally concluded three weeks earlier, but implementation had been blocked pending an appeal by the bank before the Swiss Federal Administrative Court. MBaer withdrew that appeal on 27 February 2026, allowing FINMA's orders to take effect.[1] FINMA appointed Professor Daniel Staehelin and Dr Lukas Bopp of law firm Kellerhals Carrard Basel KlG as liquidators.[2]
MBaer's board of directors resigned following the liquidation order. The bank stated that it held sufficient assets to meet all client and creditor obligations in full, though payment restrictions — arising from the revocation of its licence and the US intervention — limited transactions to Swiss francs and to a maximum of CHF 100,000 per client.[2]
FINMA also opened proceedings against four unnamed individuals believed to have been potentially responsible for violations of supervisory law in connection with the matters under investigation.[3]