The history of the Swiss banking center is a rich one. Yet for a domestic bank to be branded a «primary money laundering concern» by the US agency FinCEN (an authority recently profiled by finews) and formally threatened with exclusion from dollar clearing is an event without precedent.

And that is precisely what befell MBaer Merchant Bank on February 26, 2026. In late February, FinCEN published its 15-page «Notice of Proposed Rulemaking» (NPRM) – the proposed measure to bar any financial institution from acting as a US-dollar correspondent bank for MBaer (finews reported, article in German).

The result was a wave of negative publicity for the Swiss banking center. «How a Dirty Money Trail From Venezuela to Iran Brought Down a Swiss Bank» ran the headline at «Bloomberg», for example.

A Swiss bank as a hub for Venezuelan, Russian, and Iranian dirty money: that was the formula in which the story traveled around the globe.

The Outrage Has Yet to Subside

It was exactly the kind of story no one wanted to read again – not since the end of tax-related banking secrecy obliged the financial center to play by the international rules.

Bank founder Michael Baer became a pariah in the Swiss media and across the financial center. To this day the outrage has not died down.

The mere mention of his name is enough to send even seasoned, senior private bankers up the wall.

The Most Important Document

finews took a closer look. Drawing on numerous conversations with independent experts and people familiar with the matter, we have analyzed the case, and we will publish our findings in a loose series.

Start with the most important document: the «Notice of Proposed Rulemaking» of February 26, which broke the bank's neck. In strictly legal terms it is merely the announcement of a proposal by FinCEN, on which anyone – including those affected – may comment within 30 days.

In practice, though, such a document is fatal. Within hours, JP Morgan halted its services as a correspondent bank for dollar transactions; Zuercher Kantonalbank (ZKB) did much the same for franc transactions. And the board of directors resigned «in corpore».

An NPRM is not preceded by any evidence-gathering conducted under due-process principles. FinCEN simply puts assertions on the record – and that instantly pulls the commercial ground out from under any bank.

So what do these assertions look like in detail in the MBaer case? And what can be gleaned from the four submissions filed by individuals named in the NPRM?

Dubious Allegations

The first and most detailed evidentiary section of the order is titled «MBaer's Beginnings Anchored in Venezuela Corruption». Founded in December 2018, the bank allegedly became a landing spot for flight capital from the PDVSA corruption complex almost from the outset.

A kind of shadow bank, in other words, for the crooked regime of Nicolas Maduro.

On timing alone, that looks implausible. MBaer Merchant Bank was founded only in 2018 – just as the PDVSA scandal was detonating at other Swiss institutions.

Between 2015 and 2021, Finma examined nearly 30 banks in this context. Measures were taken against five: Julius Baer, Credit Suisse, CBH, Banca Zarattini, and Credinvest.

In other words, by the time MBaer was founded, regulators already had their hands on this money. You would have had to be out of your mind to build a new bank out of precisely that milieu – and, indeed, nothing is known of any Venezuelan clients at MBaer.

Built on Sand

At the heart of the Venezuela allegation, from the very start, stood the married couple Alessandro Bazzoni and Siri Evjemo-Nysveen. Until his temporary sanctioning by the Office of Foreign Assets Control (OFAC), Bazzoni was a small shareholder in MBaer, holding a stake of well below one percent.

His wife served for a time as vice chair of the board – with Finma's blessing.

The entire accusation in the NPRM reads, verbatim, that Evjemo-Nysveen «reportedly used her position to further payments through MBaer related to a PdVSA corruption scheme after OFAC's designation of PdVSA» – and did so, again «reportedly», on behalf of her husband.

Nothing more concrete links the couple to the PDVSA complex. In 2015, through CT Energy Holding, which he co-controlled, Bazzoni took a stake in Harvest Natural Resources, which owns an oil field in Venezuela.

Harvest Natural Resources is a company officially listed on the New York Stock Exchange. As a result, Bazzoni was sanctioned by OFAC on January 19, 2021 – only to be let off the hook four years later, on January 13, 2025. Evidently, there was nothing substantial against him.

The sanctioning quickly prompted Bazzoni to part with his MBaer shares.

Represented by the law firm Steptoe, both Bazzoni and his wife filed publicly available comments with FinCEN. Evjemo-Nysveen states that Finma comprehensively reviewed MBaer and all of its banking activities without ever making an adverse finding against her personally.

Bazzoni, for his part, confirms his former minority stake in MBaer but plays it down as a «miniscule position» held for less than a year.

And the airline Plus Ultra Líneas Aéreas – whose pandemic emergency loans FinCEN links to a «Swiss investor» – denies any knowledge of a Venezuela connection and, in its own submission, identifies the backer as Dutch, not Swiss.

Finally, Jose Luis Chavez Calva – whom FinCEN calls «a key figure involved in laundering billions of dollars obtained through PdVSA corruption» – has his law firm, Paul Hastings, point out that this claim rests on exactly two Latin American blog posts.

These are sites not even covered by media-bias rating services, and ones that themselves disclaim any warranty for their content.

His lawyer further argues that Chavez Calva is the only one of the seven individuals named in the order who was neither sanctioned by OFAC nor ever an employee, officer, or shareholder of MBaer.

That leaves the alleged Venezuelan founding story resting on a remarkably thin foundation. All four people whom FinCEN places in the PDVSA orbit dispute that alleged role with lawyerly force.

And FinCEN is unable to document the claimed nexus through even a single concrete transaction.

On the Venezuela complex, there is no reference whatsoever to «non-public information». Every statement in the NPRM rests solely on South American press and blog sources – «reportedly» and «allegedly», in FinCEN's own words.

It is thus the most weakly evidenced part of the entire order – and, of all things, the one that takes up the most space and is meant to tell the bank's founding story.

An Approach That Raises Questions

And on Iran and Russia? Here FinCEN does claim to hold its own non-public transaction data, which it explicitly describes as «according to non-public information available to FinCEN».

Yet the agency likewise consistently softens the criminal or sanctions-law characterization of that data with «assesses», «likely», «indicative of», or «allegedly».

In the case of Medvedchuk, an alleged MBaer client, FinCEN cites an exact sum – $14.3 million in round-figure payments to a Russian account of the same name – but qualifies the money-laundering characterization with «indicative of».

And with a single transfer of exactly $10 million to a Russian account holder, the amount is hard, but the identification of the person as part of an «alleged Moscow-based kleptocratic scheme» is again hedged.

Even in the alleged Iran case, Turkoca – at more than $37 million the single largest item in the entire order – FinCEN writes that the payments stand «likely in connection with» an oil-smuggling scheme run by Iran's Revolutionary Guards.

The dollar figure may be solid, but the alleged criminal structure behind it remains, as merely «likely», a bare assertion.

Once its own hedges are stripped out, little remains of the publicly presented evidence. That raises the real question.

How can such a thinly documented file lead, of all things, to the sharpest measure in FinCEN's entire arsenal – against a bank that barely registers on the international stage?

Were the Measures Coordinated?

The authorities on both sides of the Atlantic are pointedly tight-lipped when it comes to their communication or coordination with one another. Back in February, Finma did write: «Finma is in contact with FinCEN. The Financial Market Supervision Act and a bilateral Memorandum of Understanding (MoU) between the authorities provide the basis for this contact.»

WilmerHale, a specialized American law firm with numerous former senior officials from OFAC and the US Department of Justice (DOJ) in its ranks, by contrast publicly suggests that the authorities coordinated their measures to support the liquidation ordered by Finma: «It is possible that the parallel FinCEN and Finma inquiries, which were sustained over many years, were coordinated in a way to permit Swiss authorities sufficient time and process to liquidate MBaer rapidly after the public announcement of the US measures.»

Asked by finews, Finma would neither confirm nor deny this claim. It again stressed the already-known chronology: its own enforcement proceedings had been concluded in early February 2026, roughly three weeks before the FinCEN publication.

Enforcement and communication, however, had been blocked because the Federal Administrative Court had granted MBaer's appeal suspensive effect.

Finma also confirmed a case-related exchange with FinCEN, based on the MoU mentioned above – but, even on repeated questioning, declined to say when that exchange on the MBaer matter began.

WilmerHale, for its part, refuses to elaborate on its published statements about the authorities' communication or to reconcile them with Finma's chronology. It also leaves unanswered the question of whether the firm held a mandate in connection with the MBaer case.

FinCEN itself, asked by finews, merely pointed to its own already-published press release and declined any further comment.

This opacity is uncomfortable – and not only for MBaer, but for every other small Swiss bank that must now ask whether it could be next in line.

A Warning Sign for Swiss Banks

Measured by balance-sheet size (around 700 million Swiss francs, or some $875 million), assets under management (about 5 billion francs), and its category 5 rating from Finma, MBaer was one of the smallest and least significant banks in Switzerland.

And the modest volume of the payments FinCEN uses as its reference – just over $100 million spread across several years, and not even unambiguously anchored in illegality – makes the case seem all the more bizarre.

Even so, it is no accident that such a peripheral bank is finished off with FinCEN's sharpest weapon. The agency is itself required to draw up a kind of cost-benefit analysis before issuing an NPRM.

For larger institutions more tightly bound to the US financial system, that analysis would likely not come out as clear-cut as it did for MBaer.

In that sense, the MBaer case must be read as a warning sign for all smaller Swiss banks – especially those active in the less-regulated and potentially more treacherous field of trade finance.

finews asked Finma and the Swiss Bankers Association how they assess the risk of a similar FinCEN intervention against other Swiss banks. Neither organization was willing to comment.

The DOJ and FinCEN, too, when asked by finews, gave no information on whether measures against further banks are in preparation.