On June 18, 2026, a federal judge in the Eastern District of New York granted a proposed order dismissing the criminal indictments of Loyal Bank Ltd., an offshore bank based in Saint Vincent and the Grenadines, with prejudice. According to the order, federal prosecutors sought the dismissal because the bank had fully complied with the terms of its deferred prosecution agreement (“DPA”), which deferred prosecution for one year and required the bank to cooperate with the government’s investigation, report any credible evidence of money laundering or tax evasion, and pay a $2,000,000 criminal monetary penalty. The dismissal also conforms with a DPA provision in which the government agreed to dismiss the indictments within six months of the DPA’s expiration if the bank had fully complied with its obligations. Because the bank had been liquidated, counsel for the Joint Liquidators of Loyal Bank certified on or about April 15, 2026, that the DPA had expired on or about December 20, 2025, and that Loyal Bank had fulfilled its obligations under the DPA.
Loyal Bank and two of its former executives were among several defendants charged in a multicount indictment that was unsealed on March 1, 2018, for their alleged roles in a $50 million international securities fraud and money laundering scheme, which included the attempted sale of a Pablo Picasso painting in an effort to launder fraudulent profits from a related stock manipulation scheme. According to the DPA, which was signed in December 2024, the Saint Vincent and Grenadines Financial Service Authority (“FSA”) placed certain restrictions on Loyal Bank following its indictment and ordered an independent examination of the bank’s financial position, which revealed that the bank was asset deficient. The FSA ultimately declared the bank insolvent and appointed the Joint Liquidators to wind-up and liquidate the bank. The Joint Liquidators – who reportedly had no prior knowledge of or responsibility for the charged conduct – agreed to cooperate with U.S. authorities and entered into the DPA on Royal Bank’s behalf. The Joint Liquidators pleaded guilty to conspiracy to defraud the United States for failing to comply with the Foreign Account Tax Compliance Act (“FATCA”), which requires foreign financial institutions to identify their U.S. customers and report information about financial accounts held by U.S. taxpayers.
Just weeks after the March 2018 indictment, federal prosecutors announced that four individuals, including the two former executives of Loyal Bank, were charged with conspiracy to defraud the United States for violating the FATCA, as part of a five-count superseding indictment. Adrian Baron, the former Chief Business Officer and former Chief Executive Officer of Loyal Bank, pleaded guilty to the charge against him in September 2018 and, according to federal prosecutors, was the first person ever convicted in the United States for failing to comply with the FATCA. According to U.S. Immigration and Customs Enforcement, he received credit for time spent in the custody of Hungarian law enforcement and was sentenced in the Eastern District of New York to time served, fined $25,000, and ordered removed to the United Kingdom. The case against Linda Bullock, the former Head of Compliance and former CEO of Loyal Bank, continues.
Order | Unopposed Motion to Dismiss Indictments | DPA | USAO EDNY Press Release – March 22, 2018 | USAO EDNY Press Release – March 22, 2018 | USAO EDNY Press Release – September 11, 2018 | U.S. Immigration and Customs Enforcement – February 22, 2019