The United States’s financial intelligence unit (FinCEN) is proposing a 311 action against ABLV Bank. FinCEN asserts that ABLV Bank is a bank of prime money laundering concern, and that the bank has an ineffective AML/CFT and sanctions regime that has made the bank attractive for actors involved in criminal activity, weapons proliferation, corruption and sanctions evasion. FinCEN also indicates that the bank has provided financial services to individuals potentially involved in North Korean procurement or export of ballistic missiles.

ABLV Bank is headquartered in Latvia, with a subsidiary in Luxembourg and representative offices in Russia, Ukraine, Belarus, Kazakhstan, Azerbaijan, Uzbekistan, Cyprus, and Hong Kong. Given the scope of the assertions from FinCEN, any bank that has transacted with ABLV Bank should be taking a hard look at those transactions.