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SFMA liquidation order for MBaer Merchant Bank AG takes effect
MBaer Merchant Bank AG withdrew its appeal, making SFMA's licence withdrawal and liquidation order effective after serious AML and risk management findings.
SFMA's liquidation order for MBaer Merchant Bank AG is now effective after the bank withdrew its appeal. In enforcement proceedings concluded three weeks earlier, SFMA withdrew the bank's licence after finding that its anti-money laundering structure was inadequate and enabled clients to circumvent official asset freezes.
SFMA identified serious and systematic shortcomings in anti-money laundering due diligence, administrative organisation and risk management. The deficiencies particularly concerned clients linked to Swiss or international sanctions. The bank enabled clients to bypass official asset freezes.
The proceedings had been pending before the Federal Administrative Court after the bank appealed. The appeal had suspensive effect and prevented SFMA from communicating and enforcing the liquidation. With the appeal withdrawn, SFMA's orders now apply. SFMA appointed Prof. Daniel Staehelin and Dr Lukas Bopp of Kellerhals Carrard KIG Basel as liquidators.
The previous day, the US Financial Crimes Enforcement Network recommended measures under Section 311 of the USA PATRIOT Act and classified MBaer Merchant Bank AG as a financial institution of primary money laundering concern. The proposed US measure is under public consultation.
Serious breaches of supervisory law
SFMA opened enforcement proceedings in 2024 and appointed an investigating agent after examining client groups connected to Russia-related sanctions or criminal proceedings. The investigation found that 80% of business relationships carried increased risks and that, most recently, 98% of received assets came from high-risk clients.
The bank repeatedly ignored compliance recommendations without comprehensible reasons, failed to adequately investigate business relationships and transactions, and in some cases did not meet AMLA reporting duties or reported far too late. It also executed transactions for clients on sanction lists or whose funds were frozen by domestic criminal authorities. There were specific indications that the bank actively helped clients circumvent official asset freezes.
SFMA found that the bank lacked sufficient anti-money laundering measures and did not have an appropriate organisation to monitor risks. Its conduct and organisation exposed the bank and the Swiss financial centre to disproportionate risks and breached anti-money laundering rules, organisational and risk management requirements, and proper business conduct standards.
SFMA considered the case extremely serious. The requirements for proper business conduct and organisation were no longer met, and the systematic deficiencies could not be corrected in the circumstances. SFMA has also opened proceedings in four cases against individuals who may have been responsible for supervisory-law breaches.
MBaer Merchant Bank AG is a Zurich-based bank active in private client and transaction banking. At the end of 2025, it held CHF 4.9 billion in client assets, maintained almost 700 client relationships and had more than 60 employees.