Financial Settlement in Andorra: BPA Case and 2025 Convictions

The Banca Privada d’Andorra money laundering case began on March 10, 2015, when the U.S. Treasury’s Financial Crimes Enforcement Network branded the Andorran bank a “foreign financial institution of primary money laundering concern” and accused it of moving billions for Venezuelan officials, Russian organized crime, and a Chinese trade-based laundering ring.¹ Within weeks the bank was seized by Andorran regulators and broken up. A decade later, in July 2025, an Andorran court convicted 18 former BPA executives and staff, handing down 84 years of combined prison sentences and €66 million in fines, and a separate Andorran investigation is now examining whether senior Spanish officials engineered the bank’s downfall for political reasons.²

What FinCEN Accused the Bank of Doing

FinCEN’s designation, issued under Section 311 of the USA PATRIOT Act, described BPA as an “easy vehicle” for laundering because of “corrupt high-level managers and weak anti-money laundering controls.”³ The proposed rule would have barred U.S. banks from maintaining correspondent accounts for BPA, cutting it off from the dollar system.⁴ The agency laid out three separate laundering operations, each aided by senior managers at the Andorra headquarters.

Venezuelan PDVSA Funds

The largest scheme involved the Venezuelan state oil company, Petróleos de Venezuela. FinCEN said a high-level BPA manager took commissions to set up shell companies and financial products that siphoned money out of PDVSA. The bank processed roughly $2 billion in related transactions, and FinCEN’s formal finding put total transfers tied to Venezuelan laundering at approximately $4.2 billion, with at least $50 million routed through the U.S. financial system between 2011 and 2013.³ The network drew in Venezuelan officials, resident agents in Panama, and an Andorran lawyer using Panamanian shells to move funds.⁵

Several Venezuelan figures connected to the scheme were later arrested. Diego José Salazar, a cousin of former energy minister Rafael Ramírez, was detained in Venezuela in December 2017. Nervis Villalobos, a former vice-minister for energy, was arrested in Madrid at the request of U.S. authorities. Luis Carlos de León Pérez, a former in-house PDVSA lawyer, was arrested in Madrid in October 2017 in a related corruption case.⁶

Russian Organized Crime

The second scheme centered on Andrei Petrov, whom FinCEN described as a third-party launderer working for Russian criminal organizations. From 2011 until his arrest in February 2013, a senior BPA manager provided what the agency called “substantial assistance” to Petrov, including helping him get a line of credit from a Spanish bank after his initial application was rejected. Petrov allegedly laundered around 56 million euros and is suspected of ties to Semion Mogilevich, one of the FBI’s ten most-wanted fugitives.⁷

Chinese Trade-Based Laundering

The third operation involved Gao Ping, a Chinese businessman based in Spain whose network mixed trade-based laundering with human trafficking. Between 2011 and 2012, Ping’s associates paid bribes to BPA officials to accept bulk cash deposits into accounts that faced less scrutiny, then wired the money to suspected shell companies in China. FinCEN put the volume at roughly 20 million euros. Spanish police arrested Gao Ping in September 2012 as part of “Operation Emperador.”³

How the Bank Was Dismantled

The designation destroyed BPA within weeks. On March 10, 2015, the Andorran banking supervisor INAF approved a precautionary intervention and the next day suspended the board, replacing it with three provisional administrators.⁸ CEO Joan Pau Miquel Prats was arrested and sent to preventive prison. The government capped withdrawals at €2,500 per account per week to prevent a run.⁹

In April 2015, Andorra created a resolution agency called AREB. Legitimate accounts and clients were transferred, after individual screening for laundering risk, to a new bridge bank named Vall Banc in July 2015.¹⁰ By August, Fitch downgraded BPA to “D” for default, confirming it had entered winding-up proceedings.¹¹ In April 2016, AREB sold Vall Banc to the American private equity firm J.C. Flowers & Co. for up to 29 million euros, with 7.5 million paid upfront and the rest tied to performance.¹² J.C. Flowers later resold the bank to Andorra’s largest lender, Crèdit Andorrà, which completed the acquisition in February 2022.¹³

With BPA effectively shut down, FinCEN withdrew its designation and its proposed rule on March 4, 2016, saying the laundering risks had been mitigated. No special measures were ever formally imposed on U.S. banks, and FinCEN did not levy any monetary fine against BPA itself.¹⁰ The Spanish subsidiary, Banco de Madrid, was placed under intervention by the Bank of Spain the same week the FinCEN notice landed and filed for insolvency on March 16, 2015; Spanish courts later found the subsidiary not guilty of money laundering in proceedings running from 2017 to 2019.¹⁴

The July 2025 Convictions

In July 2025, an Andorran court handed down the first criminal verdict tied to BPA’s collapse. Eighteen former executives and employees were convicted of laundering €70 million for Gao Ping’s network between 2008 and 2011. Combined sentences reached 84 years of imprisonment and €66 million in fines. Six defendants were acquitted.²

Former CEO Joan Pau Miquel drew the heaviest individual sentence: seven years in prison and a €30 million fine. Former deputy director Santiago de Rosselló received six years and a €12 million fine. Other sentences ranged from three and a half to seven years. The court also barred all convicted individuals from working in banking and ordered several non-Andorran defendants expelled from the country for ten years.¹⁵

The trial began in 2018 and ran for 195 court sessions. The ruling stretched to over 6,000 pages, and the court deliberated for 20 months before releasing it.¹⁵ This is a first-instance verdict, and the defendants may appeal to the criminal division of the Superior Court. As of late 2025 they were doing so.¹⁴ OCCRP described the ruling as the “first of several cases” tied to the bank’s collapse, meaning additional trials could follow.

The Cierco Family’s Legal Fight

The Cierco family, which held 75 percent of BPA’s equity, has fought the case on multiple fronts, arguing the bank’s destruction was politically motivated. In July 2015 the family announced plans to sue Andorra over what it called an “indiscriminate and unilateral expropriation” of their assets.¹⁶

In the United States, brothers Ramon and Higini Cierco sued the Treasury Department to challenge FinCEN’s designation. A federal district court in Washington dismissed the case as moot because FinCEN had already withdrawn the finding, and in June 2026 a federal appeals court upheld that dismissal, rejecting the Ciercos’ attempt to attack the underlying evidence.¹⁷ The family then filed a new Washington lawsuit seeking to force release of correspondence between FinCEN and Andorran authorities. In Spain, they filed a €375 million damages claim against the Spanish government, and in 2016 Higini Cierco and Miquel filed a criminal complaint in Andorra against former Spanish Prime Minister Mariano Rajoy and members of his government.¹⁸

The Operation Catalonia Allegations

The BPA case has become entangled with one of Spain’s biggest political scandals. Former Spanish police commissioner José Manuel Villarejo testified to Andorran courts that he took part in a covert operation, widely known as “Operation Catalonia,” to pressure BPA into surrendering private account information on Catalan independence leaders, particularly former Catalan president Jordi Pujol and his family.¹⁹

According to Villarejo, when BPA refused to cooperate, Spanish officials fed misleading information to FinCEN to trigger the bank’s liquidation. He named Rajoy as the orchestrator and also implicated former Interior Minister Jorge Fernández Díaz, former Finance Minister Cristóbal Montoro, and other senior officials.²⁰

Andorran judge Stephanie Garcia opened a formal investigation after a 2020 lawsuit by the Andorran Institute for Human Rights and Higini Cierco. She has asked Spanish courts to notify six former officials that they are under investigation.²⁰ Spanish courts have declined to open their own investigation, making the Andorran proceeding the only active judicial inquiry into these allegations. In December 2025, BPA shareholders formally asked Andorran officials to declassify documents about what authorities knew before the FinCEN designation.¹⁴

The claims remain contested. Andorra’s current prime minister, Xavier Espot, has denied that official Spanish state pressure influenced the 2015 decision, though he has acknowledged reports that Spanish police tried to pressure bank executives for information.¹⁹

What Changed in Andorran Banking After BPA

The scandal accelerated reforms that had begun in 2009, when Andorra signed the Paris Declaration committing to end its banking secrecy tradition. In 2017 Andorra enacted Law 14/2017 on the prevention of money laundering and terrorist financing, transposing the EU’s Fourth Anti-Money Laundering Directive, and amended its Penal Code to criminalize tax evasion for the first time, with penalties of up to five years’ imprisonment.²¹²²

The Council of Europe’s MONEYVAL committee praised the “sweeping changes to legislation” in a 2017 assessment but noted that the ratio of investigations to prosecutions and convictions remained “modest” and that the financial intelligence unit, UIFAND, was hampered by limited resources.²² Andorran banks must now identify clients and beneficial owners before opening accounts, file suspicious transaction reports, run risk-based due diligence, and submit to independent external AML audits.²³ Andorra remains one of the few major jurisdictions that has not signed a FATCA intergovernmental agreement with the United States, a point raised in 2023 by U.S. Senate Finance Committee Chairman Ron Wyden when questioning another Andorran lender, Andbank, about a separate tax evasion inquiry.²⁴

1
FinCEN. FinCEN Names Banca Privada d’Andorra Foreign Financial Institution of Primary Money Laundering Concern
2
Ara.cat. First Ruling in the BPA Case: 18 Convicted, 84 Years in Prison and 66 Million in Fines
3
FinCEN. Notice of Finding That Banca Privada d’Andorra Is a Financial Institution of Primary Money Laundering Concern
4
Federal Register. Imposition of Special Measure Against Banca Privada d’Andorra as a Financial Institution of Primary Money Laundering Concern
5
CNN. Andorra Russia China Dirty Cash
6
El País. Andorra Corruption Scheme Venezuelan Officials
7
Federal Register. Notice of Finding That Banca Privada d’Andorra Is a Financial Institution of Primary Money Laundering Concern
8
Banco de España. Briefing Note on Banca Privada d’Andorra and Banco de Madrid
9
El País. Andorra Bank BPA Banco Madrid Intervention
10
Federal Register. Withdrawal of Finding Regarding Banca Privada d’Andorra
11
Fitch Ratings. Fitch Downgrades Banca Privada d’Andorra to D
12
All Andorra. AREB Decision to Sell Net Assets of BPA to J.C. Flowers
13
Creand Group. Crèdit Andorrà Completes the Acquisition of 100% of Vall Banc
14
Forbes. A Bank Is Closed in Andorra and Spain’s Elite Takes a Battering
15
OCCRP. Top Andorran Bankers Jailed Over EUR 70M Laundering Plot
16
The New York Times. Banking Family Plans to File Suit Against Andorra
17
Reuters. U.S. Court Rules Against Andorran Bank Accused of Money Laundering
18
El Nacional. Higini Cierco Testimony on BPA and Pujol Family
19
Ara.cat. Villarejo Testifies to Andorran Justice System That Rajoy Forced Collapse of BPA
20
Catalan News. Former Spanish PM Under Investigation in Andorra for Discrediting Catalan Politicians
21
Andorran Banking Association. Prevention of Money Laundering and Terrorist Financing
22
Council of Europe. MONEYVAL Welcomes Reforms in Andorra
23
Chambers and Partners. Banking Regulation 2026 – Andorra Trends and Developments
24
Tax Notes. Wyden Questions Foreign Banks on Tax Evasion