In the UBS case, $48 million of the $125 million was credited in this way, drawn from SEC ($20 million), CFTC ($8 million) and FINRA ($20 million) payments. Under Political PressureOn the political front, FinCEN has for years faced criticism for being too slow and too toothless. Why the Swiss MBaer Merchant Bank landed on FinCEN's radar at all is an intriguing question whose answer remains outstanding. FinCEN Toughens Its StanceWe return to the question posed at the outset: how dangerous is FinCEN for Swiss banks? Here, too, a tougher approach is to be expected, as FinCEN has shown with its recent dollar records: TD Bank among banks, UBS Financial Services in the broker-dealer category.