Treasury Proposes Rule to Sever Swiss Bank MBaer’s Access to U.S. Financial System

FinCEN's proposal to sever MBaer's U.S. financial system access reflects a failure in the decision governance of correspondent banking relationships. U.S. institutions that provided MBaer with access lacked examinable records showing who approved the relationship, what sanctions and beneficial ownership evidence supported that approval, and when periodic reviews validated ongoing eligibility. A decision record system capturing owner, rationale, evidence, and outcome at each approval and review milestone would have either prevented the relationship or created an audit trail demonstrating diligence when regulators sought accountability for facilitation of illicit actors.