The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking that would, if finalized, cut off MBaer Merchant Bank AG’s access to the U.S. financial system by prohibiting covered U.S. financial institutions from opening or maintaining correspondent accounts for, or on behalf of, MBaer. The proposal is tied to alleged financial support provided by MBaer to illicit actors linked to Russia and Iran. FinCEN set out a finding that reasonable grounds exist to conclude MBaer is a foreign financial institution of primary money laundering concern and proposed imposing “special measure five” under section 311 of the USA PATRIOT Act. The notice describes MBaer as having enabled money laundering and illicit finance, including facilitating corruption linked to Russian money laundering and money laundering and terrorist financing on behalf of Iran-aligned foreign terrorist organizations, including the Islamic Revolutionary Guard Corps and its Quds Force, and states the bank has funneled over USD 100 million through the U.S. financial system. Written comments on the proposal may be submitted within 30 days of its publication in the Federal Register.