The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking that would, if finalized, sever MBaer Merchant Bank AG’s access to the US financial system, citing the bank’s financial support to illicit actors linked to Russia and Iran. The proposal would prohibit covered US financial institutions from opening or maintaining a correspondent account for, or on behalf of, MBaer. The rulemaking frames MBaer, a Swiss bank, as a financial institution operating outside the United States of primary money laundering concern and would implement the restriction through a “special measure” focused on correspondent account access.