Iran War Reveals Sanctions Evasion via Swiss Banks
Summary
This law firm analysis examines how escalating Iran tensions have illuminated international money laundering through Swiss banks, focusing on FinCEN's February 26, 2026 action naming Merchant Bank AG (MBaer) a primary money laundering concern for facilitating Iranian sanctions evasion via the IRGC and Quds Force. The article also references recent Swiss bank enforcement actions including J. Safra Sarasin SA (3.5 million Swiss francs fine) and Pictet Bank (2 million Swiss francs fine) for unrelated money laundering matters, providing context on the pattern of Swiss banking scrutiny.
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What changed
This JD Supra article from Flaster Greenberg PC provides legal commentary on existing regulatory enforcement actions rather than creating new compliance obligations. The analysis centers on FinCEN's February 26, 2026 designation of Swiss bank Merchant Bank AG as a primary money laundering concern, with the article contextualizing this action within the broader Iran conflict and historical Swiss banking scrutiny. The article synthesizes recent enforcement precedent including penalties against J. Safra Sarasin SA and Pictet Bank.
Affected parties—including financial institutions with exposure to Swiss correspondent banking relationships or energy-sector clients with potential Iranian nexus—should monitor FinCEN's ongoing MBaer rulemaking proceeding. The article's historical overview of Swiss bank controversies (tuna bonds scandal, Holocaust-era restitution) illustrates recurring compliance vulnerabilities that Swiss institutions face, suggesting enhanced due diligence expectations for U.S. banks interacting with Swiss counterparties.
Archived snapshot
Apr 25, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
April 24, 2026
Iran War Shines Light on International Money Laundering
Daniel Markind Flaster Greenberg PC + Follow Contact LinkedIn Facebook X ;) Embed Iran's refusal to meet key U.S. terms is threatening global oil and liquid natural gas supply. U.S. CENTCOM imposed a blockade on ships transiting the Strait of Hormuz that either depart from or call at Iranian ports, beginning 10 a.m. Eastern Tuesday, April 13 th and announced that the blockade had been fully implemented on the morning of April 15 th.This was ordered by President Donald Trump after the delegation, headed by Vice President JD Vance, was sent to Islamabad, Pakistan, to negotiate with representatives of the Iranian regime and returned home without reaching a deal. Reports are circulating that talks may resume, and even that a deal may be reached before the April 22 nd deadline for the ceasefire. However, even before the peace talks began, the Iranians had listed four “non-negotiable” demands that make this conflict hard to settle quickly and easily. The demands were: (1) full sovereignty over the Strait of Hormuz; (2); complete war reparations to be paid to Tehran; (3) unconditional release of Iranian frozen assets; and (4) a full ceasefire between Israel and Hezbollah in Lebanon.
Three of Tehran’s four demands relate directly to finances, with control over the strait entailing the ability to extort tribute money, which is a blatant threat to the global commons and a violation of international maritime law. Clearly, access to cash is paramount for Iran. Over the last few decades, as the regime has increasingly faced international sanctions, it has sought to evade them, with the sale of its energy reserves as a key source of income. With much of the Western banking system having been closed to Iran for so long, it is relevant to ask how exactly did Iran finance its military build-up, nuclear weapons program, and the billions of dollars that it has sent to its proxies like Hezbollah, Hamas, and the Houthis over the years?
One clue may come from the center of international banking, Switzerland. Often accused of being a safe haven for the laundering of so-called “dirty money,” Swiss banks now find themselves being increasingly scrutinized for, yet another money laundering scheme directly related to energy sales.
Specifically, on February 26, 2026, the United States government accused the Swiss bank, Merchant Bank AG (MBaer), of being a “primary money laundering concern.” More particularly, in announcing its proposal of a rule to sever MBaer’s access to U.S. financial systems, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) claimed that MBaer, “…has facilitated money laundering and illicit financial transactions relating to malign Russian and Iranian activities. MBaer’s role has enabled evasion of sanctions and export controls by foreign terrorist organizations such as Iran’s Islamic Revolutionary Guard Corps (IRGC) and its Quds Force (IRGC-QF).”
The reality is that accusations like this are nothing new for Swiss banks, especially when it comes either to accusations relating to energy transactions or to attempts by Swiss banks to clean up their reputations for involvement with funds diverted from developing countries worldwide, such as Haiti, the Philippines, the Democratic Republic of the Congo and many others.
Just last year, the Swiss bank J. Safra Sarasin SA was fined 3.5 million Swiss francs ($4.3 million) by the Swiss government for corruption and money laundering involving Brazil’s state-owned oil company Petrobras. Also in 2025, another local Swiss institution, Pictet Bank, was fined 2 million Swiss francs ($2.5 million) for money laundering involving Petrobras.
In December 2025, Swiss federal prosecutors filed charges against (failed) Credit Suisse and its new owner, UBS, over an affair known as the “tuna bonds” loan scandal. This scheme involved some $2 billion in secret loans spearheaded by Credit Suisse and the Russian bank VTB Capital and guaranteed by the government of Mozambique for maritime projects such as tuna fishing and shipyard construction from 2013 to 2014. These loans also involved some $200 million in bribes and kickbacks. When the situation came to light, the IMF suspended lending and budget support, other investors pulled in their loans, and the Mozambique economy cratered in 2016, sending shockwaves across Africa and prompting the U.S. Department of Justice to file charges.
Whether deserved or not, Swiss banks have a long reputation of being too close to dirty money. During World War II, of course, Swiss banks were the financial houses of choice for Nazi transactions involving gold and other valuables plundered from the reserves of occupied nations or Holocaust victims. After World War II ended, Switzerland refused to return the money and valuables to Holocaust victims or their heirs. It was only in 1988, following a lawsuit initiated by the World Jewish Congress, that UBS and Credit Suisse agreed to pay $1.25 billion in compensation.
Swiss banks have also been accused of more than just being places to park ill-gotten money. In 2015, HSBC Holdings PLC was shown to have actively facilitated tax evasion and money laundering schemes by creating offshore structures to conceal beneficial ownership.
While Swiss banks have long tried to portray themselves as neutral international actors, who are above international politics, the banks in that country has not always acted that way, and they have not always been immune from international pressure as well, often involving energy assets. For example, on January 5, 2026, the Swiss Federal Council announced that it was freezing the assets of Venezuelan President Nicolas Maduro and his associates, and in February, the Swiss foreign ministry announced that additional funds had been frozen, bringing the total to 687 million Swiss francs (over US$872 million).
The obvious question is, would this have even occurred had Maduro not been deposed, or would the Swiss banks have continued to simply accept so much money that it arguably came from oil wealth belonging to the Venezuelan people?
Indeed, the opacity of oil wealth is only a small part of what Swiss banks have been accused of. In the book Qatar Papers: How the Emirate Finances Islam in France and Europe (2019), French journalists accused Switzerland of being a safe haven for the Muslim Brotherhood. If this is true, it would make Switzerland an important center of Islamist influence in Europe.
The list of shady conduct by Switzerland’s financial community goes on. As early as 2020, Swiss banks were being accused of helping Venezuela’s “ boligarchs ” to smuggle billions of oil wealth out of that country. The Maduro matter shows that the banks continued the practice regardless of the international anger and opprobrium.
Will the same be true for Iran? The Iranians clearly are desperate for money. Estimates are that Iran has suffered $145 billion in war losses and destruction. Even before the “40-day war” started, Iran was running out of water. It desperately needs money to support its own population and to help rebuild its infrastructure, let alone fund the war effort. If it turns to Swiss banks, as is likely, what will they do? Given their unfortunate historical track record when it comes to providing a platform for the handling of so-called “dirty money”, the likely answer is not difficult to guess.
;) ;) Report
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