Joan Pau Miquel, former CEO of Banca Privada d’Andorra, has been sentenced to seven years in prison and fined €30 million for his central role in a €70 million money laundering scheme, while former deputy director Santiago de Rosselló received six years and a €12 million fine. These record sentences are the result of an extraordinarily complex legal process, with the court’s ruling stretching over 6,000 pages and 20 months of deliberation. The case began in 2018 and required 195 days of hearings, each lasting six hours, reflecting the scale and sophistication of the alleged criminal activity. BPA was shut down after a FinCEN designation, with its assets moved to other banks. Although the court did not officially name the primary client, Spanish and Andorran media linked the scheme to Chinese businessman Gao Ping, accused of orchestrating wide-scale tax fraud and money laundering across Spain between 2010 and 2012.
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Andorra Money Laundering Case: Anatomy of the BPA Scandal
The downfall of Banca Privada d’Andorra traces back to 2015 when the U.S. Financial Crimes Enforcement Network (FinCEN) publicly designated BPA as a primary money laundering concern. This rare action triggered immediate global scrutiny. According to official statements and legal filings, FinCEN had uncovered evidence that senior BPA management facilitated illicit transactions for organized crime networks, including proceeds linked to Russia, China, and foreign corruption.
The Andorran justice system responded with a sweeping investigation, leading to criminal charges against 18 of the bank’s executives. Judicial proceedings were notable for their scale and rigor, spanning nearly two years and culminating in a 6,000-page verdict. Each defendant was individually examined for their role in facilitating, authorizing, or ignoring suspicious activity, with authorities meticulously tracing the flow of funds through bank accounts across multiple jurisdictions.
Although the official judgment did not name the principal client behind the largest transactions, sources in Spain and Andorra identified Chinese businessman Gao Ping as a key figure. Gao had previously come under the radar of Spanish prosecutors for orchestrating tax evasion and money laundering schemes within Spain’s Chinese business community. The sum laundered through BPA—estimated at €70 million—has made this case one of the most significant financial crime scandals in Andorran history.
BPA Case: The Compliance and Regulatory Fallout
The FinCEN designation had immediate and far-reaching consequences for BPA and Andorra’s wider financial ecosystem. Andorran authorities moved quickly to freeze assets, impose controls, and eventually dismantle the bank, transferring legitimate assets to other institutions. The BPA affair exposed systemic compliance failures, both at the management and operational levels.
Among those sentenced, Joan Pau Miquel, the former CEO of BPA, received the harshest penalty with seven years in prison and a €30 million fine. Other top executives, including the deputy director, were given multi-year sentences and substantial financial penalties. The court also barred several individuals from working in the financial sector and, for non-Andorran staff, mandated expulsion from the country.
The case has forced Andorra to implement sweeping reforms. Since 2015, the principality has enhanced its anti-money laundering (AML) regime, bringing local standards in line with the Financial Action Task Force (FATF) recommendations. The new regulatory architecture established stricter customer due diligence, increased reporting obligations, and improved cooperation with international law enforcement agencies.
This case also drew attention from the European Union, which had raised concerns about Andorra’s role as a financial intermediary between larger economies. In response, Andorra strengthened its regulatory alignment with European AML directives, even as it retained a degree of banking secrecy—a core element of its financial sector’s historic appeal.
FinCEN’s Role and the International Ripple Effect
FinCEN’s 2015 action against BPA marked only the fifth time in its history that the U.S. agency had invoked Section 311 of the USA PATRIOT Act to isolate a foreign bank for facilitating money laundering. This move effectively cut BPA off from the global financial system, as correspondent banks and partners worldwide severed ties overnight.
FinCEN’s findings described systematic weaknesses in BPA’s compliance controls, especially in its private banking division. Investigators cited multiple red flags, including high-value transactions, opaque ownership structures, and a lack of effective oversight of politically exposed persons (PEPs).
The case underscored the growing international reach of AML regulators. It also demonstrated how global standards, like those set by FATF, are increasingly enforced through both direct and indirect mechanisms—especially when small financial centers serve as potential conduits for large-scale illicit finance.
Andorra, facing external pressure and internal crisis, had no choice but to accept international intervention. The immediate transfer of BPA’s “clean” assets and the shutdown of suspicious accounts demonstrated that global regulatory coordination is now the norm, not the exception.
Lessons for Compliance: Red Flags, Governance Failures, and Regulatory Response
The BPA case provides several crucial lessons for the financial industry, especially institutions operating in smaller jurisdictions:
- Governance Weaknesses: BPA’s senior leadership was complicit in enabling suspicious transactions. This highlights the need for robust internal controls, effective whistleblowing mechanisms, and independent board oversight.
- Customer Due Diligence (CDD): The failure to properly identify and verify the ultimate beneficial owners of client accounts was at the heart of the scandal. Enhanced due diligence for high-risk clients and politically exposed persons is now a regulatory expectation worldwide.
- Regulatory Cooperation: The rapid intervention by FinCEN and subsequent action by Andorran authorities demonstrates the importance of international cooperation and information sharing in fighting financial crime.
- Enforcement Trends: Multi-jurisdictional cases like BPA are likely to become more common, particularly as global agencies increasingly leverage their reach to target enablers of organized crime and corruption.
Andorra’s subsequent reforms have focused heavily on integrating FATF and EU AML requirements. The country has modernized its financial intelligence unit (UIFAND), adopted risk-based approaches, and updated reporting standards, signaling a clear commitment to preventing another BPA-style scandal.
The Ongoing Impact: Andorra’s Reputation and the Future of Banking Secrecy
The BPA affair delivered a major shock to Andorra’s international reputation as a discreet financial center. For decades, the country had marketed itself as a safe haven for international capital. However, global shifts in AML policy and transparency requirements have eroded the advantages of banking secrecy.
Since the closure of BPA, Andorra has made considerable efforts to reposition itself as a transparent, well-regulated jurisdiction. The country’s adoption of the OECD Common Reporting Standard (CRS) and engagement with cross-border tax information exchanges have helped to rebuild trust.
Nevertheless, the shadow of the BPA case continues to loom. Financial institutions across Andorra are now subject to much tighter supervision, frequent audits, and rigorous enforcement of AML controls. The government is also actively cooperating with EU and U.S. authorities to prevent the misuse of its banking sector by foreign criminals.
Conclusion: The BPA Case and the Evolving Global AML Landscape
The conviction and sentencing of BPA’s former executives in the Andorra money laundering case serve as a powerful reminder of the risks posed by weak compliance cultures and inadequate oversight. The case underscores how even small jurisdictions can become entangled in international financial crime, with consequences that reverberate across borders.
As global regulators sharpen their focus on cross-border money laundering, Andorra’s response to the BPA affair sets a precedent for rapid, coordinated action. The country’s reforms illustrate the increasing importance of global standards, as well as the need for ongoing vigilance and adaptation in the face of evolving criminal methodologies.
For compliance professionals, the BPA scandal stands as a case study in the dangers of regulatory complacency and the critical value of strong governance, risk management, and proactive international cooperation.
Related Links
- Financial Crimes Enforcement Network (FinCEN) official statement on BPA
- Andorra’s UIFAND: Anti-Money Laundering Legislation
- FATF: International Standards on Combating Money Laundering
- European Commission: AML/CFT Directives
- OECD Common Reporting Standard (CRS)
Other FinCrime Central Articles Mentioning Andorra
Source: OCCRP, by Antonio Baquero
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