ABLV Bank and FinCEN Section 311

As of November 2026: As of November 2026 the latest primary record reviewed is FinCEN's September 2024 withdrawal, which describes the bank's liquidation as advanced and supervised by Latvia. The current state of the liquidation and the outcome of the Latvian criminal cases were not confirmed. The FinCEN allegations are claims in a regulatory notice, not court findings. The Latvian reform details come from FinCEN's 2024 notice, and the non-resident deposit figures come from a 2019 press report of a regulator official's remarks. The shareholders' liquidation decision is dated 5 March 2018 by the FCMC, and some press reports give an earlier date, so the date is not used here. Court challenges brought by the bank against the ECB and SRB were not reviewed.

Also known as: ABLV Bank liquidation · FinCEN ABLV Bank finding · ABLV Bank Latvia money laundering.

What happened?

ABLV Bank, AS was a commercial bank in Riga, Latvia, founded in 1993. FinCEN’s notice said that at the end of March 2017 it held about $4.6 billion in assets, making it Latvia’s second-largest bank and the country’s largest bank serving non-resident customers.

On 13 February 2018, the US Treasury’s FinCEN announced a finding under Section 311 of the USA PATRIOT Act that ABLV was a foreign financial institution of primary money laundering concern. It proposed the fifth and harshest special measure: US banks would be barred from opening or keeping a correspondent account for ABLV, and would have to take reasonable steps not to process its transactions indirectly. The notice appeared in the Federal Register on 16 February, with public comments due by 17 April 2018.

Within ten days, European authorities had declared the bank failing or likely to fail. The proposed rule was never finalised.

Which techniques did it use?

This section describes what FinCEN alleged. It is a regulatory notice, not a court finding, and the notice itself accepts that the bank could also be used for legitimate purposes.

• Shell company customers. FinCEN said 90 percent of ABLV’s customers were high-risk under the bank’s own methodology, mostly shell companies in secrecy jurisdictions. From 2012 to 2017, it said, transactions for these shells totalled tens of billions of dollars.
• Named schemes. The notice linked the bank to the theft of more than $1 billion from three Moldovan banks in 2014, to accounts of a Ukrainian businessman later sanctioned by OFAC, and to funds from a Russia-based bank in a pattern FinCEN called a hallmark of asset-stripping.
• North Korea links. FinCEN said ABLV facilitated transactions for parties tied to US- and UN-designated North Korean entities, some involved in ballistic missile procurement or export, and that this continued after the bank’s own summer 2017 announcement on the issue. See sanctions evasion.
• Insider complicity. FinCEN said executives, shareholders and employees made laundering a pillar of the bank’s business, and that through 2017 management used bribery to influence Latvian officials challenging enforcement actions and sought to obstruct Latvian enforcement.
• Dollar access without a US account. The bank had no direct US correspondent accounts. FinCEN said it reached dollars through nested relationships at other banks, after several US institutions had closed their direct accounts with it. This is the loophole the rule aimed to close.

How was it found?

The notice does not name a single trigger. It cites earlier warnings from supervisors: Latvia’s FCMC examined the bank and in May 2016 fined and reprimanded a board member, and the National Bank of Ukraine issued an advisory on 28 August 2016 warning Ukrainian banks about ABLV. FinCEN judged that these steps did not sufficiently protect the US financial system, and it rejected the milder special measures as inadequate.

What was the outcome?

• 13 to 23 February 2018. The ECB said depositors withdrew funds rapidly after the FinCEN announcement and the bank lost its US dollar funding. It could not make dollar payments and lacked the funds to cover stressed outflows before the deposit guarantee payout could start. At the ECB’s instruction, the FCMC imposed a moratorium. On 23 February the ECB found ABLV and its Luxembourg subsidiary failing or likely to fail.
• 24 February 2018. The Single Resolution Board decided resolution action was not in the public interest, so both banks were wound up under Latvian and Luxembourg law. Eligible deposits were protected up to €100,000.
• June to July 2018. The FCMC permitted a voluntary liquidation plan on 12 June, after an independent audit concluded that the bank had enough assets to meet creditors’ interests. The ECB withdrew the licence on 11 July.
• Luxembourg. FinCEN’s later notice says the regulator fined the subsidiary €250,000 in January 2019 for anti-money laundering failures and that courts ordered it dissolved.
• Criminal charges. FinCEN’s 2024 notice says Latvian investigations led to charges against the owners and senior managers. No outcome was confirmed.
• 26 September 2024. FinCEN withdrew the finding and proposed rule (89 FR 79184), saying the bank no longer operated as a depository institution and was in irrevocable liquidation supervised by Latvia.

What were the warning signs?

• A customer base dominated by high-risk shells. The bank’s own risk method rated 90 percent of customers as high-risk.
• Heavy dependence on non-resident deposits. FinCEN named this a principal source of concern.
• Indirect dollar access. Other banks had closed their direct accounts, yet dollar flows continued through nested relationships.
• Links to designated parties. Customers or counterparties tied to sanctioned North Korean entities and a person designated by OFAC.
• Alleged pressure on officials. FinCEN described bribery and obstruction aimed at Latvian enforcement.
• Fragile funding. The ECB found the bank could not survive a rush of withdrawals once dollar access was lost.

What changed afterwards?

FinCEN’s 2024 notice lists Latvian reforms: a ban on most transactions with shell companies in April 2018, an independent financial intelligence unit from November 2018, and further rules in 2019 and 2021 on fit-and-proper tests, beneficial ownership, enhanced due diligence for high-risk jurisdictions and suspicious transaction reporting. In July 2019 the FCMC’s acting head said about €10 billion in non-resident deposits had left Latvia, with about €3.5 billion remaining.

In February 2026 the Council of Europe’s MONEYVAL said Latvia had undergone a substantial transformation of its financial system and risk landscape since 2018, and placed it under regular follow-up. It also noted that the lack of identifiable suspects in some large historical cases had limited prosecutions.

For banks, the case showed how fast access to dollars can disappear. Compare Danske Bank and Swedbank, also Baltic non-resident cases. See know your customer for the ownership checks banks are expected to make.

First published November 4, 2026 · Last updated November 4, 2026 · Legal statuses current as of November 2026