FinCEN Blacklists Banca Privada d’Andorra

On March 10, 2015, FinCEN designated Banca Privada d'Andorra, based in the Principality of Andorra, as a foreign financial institution of primary money-laundering concern pursuant to Section 311 of the USA PATRIOT Act (Section 311). FinCEN also issued a Notice of Proposed Rulemaking under which U.S. banks would be prohibited from providing correspondent banking services to Banca Privada d'Andorra or any bank that processes transactions for Banca Privada d'Andorra. FinCEN's announcement discussed three examples of money-laundering activity that the bank allegedly facilitated.

1. A high-level manager provided substantial assistance to Andrei Petrov, a third-party money launderer working for Russian criminal organizations engaged in corruption. In February 2013, Spanish law enforcement arrested Petrov for money laundering. Petrov is also suspected of having links to Semion Mogilevich, one of the FBI's "Ten Most Wanted" fugitives.