Regulatory Intelligence

FinCEN’s §311 Move on MBaer Tests Correspondent-Chain Controls

FinCEN’s §311 NPRM proposes “special measure five” on MBaer, combining a correspondent-account prohibition with “reasonable steps” and special due diligence aimed at preventing MBaer-linked transactions from moving through U.S.-based correspondent chains—if finalized.

Laurie Shrout

10 Mar 2026 — 5 min read

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TL;DR:
FinCEN proposed a §311 special measure against MBaer that, if finalized, would bar covered U.S. financial institutions from opening or maintaining correspondent accounts for, or on behalf of, MBaer, and would require reasonable steps and special due diligence to prevent transactions involving MBaer from being processed through foreign correspondent accounts in the United States.

What you need to know

The move: FinCEN issued a §311 NPRM proposing a “special measure” against MBaer Merchant Bank AG (Switzerland) that would sever MBaer’s access to the U.S. financial system if finalized, per Treasury. (Treasury press release)
Why it matters: The proposal goes beyond direct account relationships. If finalized, it would require covered U.S. financial institutions not only to bar correspondent accounts for MBaer, but also to take reasonable steps and apply special due diligence to prevent transactions involving MBaer from moving through U.S.-based correspondent accounts for foreign banks. (Federal Register NPRM; GovInfo PDF)
Who should care: AML/sanctions leaders at banks and broker-dealers, financial crime ops teams running transaction controls, regulatory counsel drafting comments, and fintech risk leaders dependent on partner-bank rails. (Federal Register NPRM)

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