The Office of the Comptroller of the Currency on Jan. 15 granted UBS conditional approval for a national bank charter — the first step toward allowing the Swiss banking giant to offer retail services to American consumers.
Before regulators take the next step, they should read the bank’s rap sheet.
UBS has spent two decades violating U.S. sanctions, obstructing investigations, and laundering money for America’s enemies. It now carries the baggage of Credit Suisse, which it absorbed in 2023 — a bank that stripped the names of sanctioned Iranian entities from wire transfers, bankrolled Nazi ratlines, and fought to bury the evidence of both. Granting this institution a retail banking license in the United States would reward a pattern of deliberate deception at the precise moment Washington claims to be tightening the screws on Iran.
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Start with UBS’s own record. In 2004, the Federal Reserve fined UBS $100 million for funneling U.S. dollars to Cuba, Iran, Libya, and Yugoslavia through a cash depot in Zurich operated under contract with the Federal Reserve Bank of New York. The Fed found that UBS officers and employees engaged in “intentional acts aimed at concealing” the prohibited transactions. This was not a compliance gap. It was a conspiracy.
In 2015, the Treasury Department’s Office of Foreign Assets Control settled with UBS over 222 apparent violations of the Global Terrorism Sanctions Regulations — transactions processed on behalf of an individual designated under Executive Order 13224 for supporting terrorism. UBS paid $1.7 million.
In 2018, FinCEN assessed a $14.5 million penalty against UBS Financial Services for anti-money laundering failures spanning from 2004 to 2017 — 13 years during which the bank processed tens of billions of dollars in foreign currency wire transfers without capturing sender, recipient, or country-of-origin data. FinCEN’s director said the firm had become “a conduit for movement of illicit funds creating a haven for criminals and other malign actors.”
Now, add what UBS inherited.
In 2009, the Treasury, Justice Department, and the New York County District Attorney reached a $536 million settlement with Credit Suisse — at the time the largest in OFAC’s history. Credit Suisse had spent 20 years routing thousands of transactions through U.S. banks while hiding the involvement of sanctioned parties. The great majority involved Iran. OFAC called it “an egregious case” and documented how Credit Suisse “developed and deployed elaborate procedures” to alter payment instructions, strip sanctioned names from wire transfers, and falsely identify Credit Suisse itself as the ordering institution. When a Swiss regulatory requirement threatened to expose the scheme in 2004, Credit Suisse did not stop. It coached its Iranian clients on alternative methods to keep the money flowing.
This is the institutional DNA that now resides inside UBS.
And then there is the matter that no amount of compliance reform can paper over. On Feb. 3, the Senate Judiciary Committee heard testimony that an independent investigation has identified 890 previously undisclosed Credit Suisse accounts with possible Nazi links — 628 individuals and 262 entities, including wartime accounts for the German Foreign Office and a German arms manufacturer.
Investigator Neil Barofsky told the committee that Credit Suisse financed a ratline that smuggled Nazi war criminals to Argentina, which served to fund “bribes, obtain fraudulent travel documents, and pay for living expenses and transportation for fugitives, including perpetrators of the Holocaust.” Credit Suisse forcibly transferred Jewish assets into Nazi-controlled accounts.
When Barofsky dug too deep, Credit Suisse fired him. UBS rehired him after acquiring Credit Suisse — then began withholding documents. Barofsky testified that shortly after he informed UBS that the Senate was considering a hearing, the bank imposed a privilege review and started shielding relevant materials for the first time. He told senators he could not assure them that the investigation had “truly left no stone unturned.”
Sen. Chuck Grassley (R-IA), chairman of the Senate Judiciary Committee, called UBS’s conduct “absurd and a historic shame.”
This is the bank that wants to open checking accounts for American families.
The regulatory question is simple. Federal law requires the OCC to evaluate a charter applicant’s record of compliance, its management integrity, and its capacity to operate in a safe and sound manner. UBS fails on all three counts. Its compliance history is not a series of isolated incidents but a pattern: violate sanctions, conceal the violations, pay the fine, repeat. Its management inherited an institution that actively obstructed a Holocaust accountability investigation — and then continued the obstruction. Its institutional culture, demonstrated across multiple jurisdictions and decades, treats U.S. enforcement as a cost of doing business.
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The timing makes the decision even more consequential. The Trump administration has declared maximum pressure on Iran a central pillar of U.S. foreign policy. Treasury is designating Iranian oil networks and Hezbollah financiers on a near-weekly basis. Congress is passing new sanctions legislation. Under these conditions, handing a retail banking license to a conglomerate with UBS and Credit Suisse’s combined Iran sanctions record sends a message that undermines every designation, every enforcement action, and every dollar spent on financial warfare against Tehran.
American regulators have the authority and the obligation to say no. They should use it.
Gregg Roman is Executive Director of the Middle East Forum.
