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The Andorra Hustle

There's an old expression: "When an iron pot collides with a clay pot, the clay pot crumbles. When a clay pot collides with an iron pot, the clay pot crumbles." And when the United States Treasury Department collides with a bank in a country about the size of Scottsdale, Arizona, with a population of under 80,000, you can guess which one is going to crumble.

"You have probably never heard of Andorra," writer/director Eric Merola correctly predicts at the beginning of "The Andorra Hustle," his new documentary. It is a tiny little principality between France and Spain governed by "co-princes," the French president and the bishop of Urgel. Its economy is strong, based on tourism (the entire country is basically a duty-free zone) and banking. 

You have probably also never heard of Section 311, though you probably have heard of the legislation that established it: The Patriot Act. In the weeks following 9/11, Congress created some wide-ranging and unprecedented emergency powers. It seemed possible that fundamental Constitutional notions of due process might have to be reconsidered. 

It also seemed inevitable that mission creep would lead to non-emergency use of these powers, for diplomatic or strategic purposes. That, according to Merola, is what happened when a division of the US Treasury Department called the Financial Crimes Enforcement Network or FinCEN. If they issue a press release saying they have found that "reasonable grounds exist" for believing a non-US financial institution is involved in money-laundering," they essentially destroy the ability of that institution to do business. As one person says in the film, it is like stabbing someone and saying, "I stuck the knife in, but it was your decision to die." Merola calls it a bank assassination. 

FinCEN does not have to show the evidence before or after issuing the press release. They do not have to give advance warning. They do not have to explain why it is an emergency and cannot be addressed through law enforcement. They do not have to give the financial institution a chance to respond. They did none of those things when they issued the press release about Andorra's Banca Privada d’Andorra (BPA). "The Andorra Hustle" is the story of what happened when that press release was issued along with some speculation about what was really behind it.  

You have to give Merola credit for trying to untangle the insanely complicated Gordian knot of international financial regulation, illegal money laundering and its slightly-over-the-line legal versions (for more on this see "The Laundromat"), the diplomacy issues, the American lawyer challenging the validity of Section 311 in court, and the dozens of entities reviewing literally millions of transactions and tracking billions of dollars, including one of the Big Four accounting firms, PWC (they do not come across well here) and the most-respected international security firm, Kroll. Unlike Adam McKay with "The Big Short," Merola does not have the budget to put Margot Robbie in a bubble bath to hold our attention for the explanation. Instead there are just a long series of talking heads in office settings with brief animation and archival footage segments.

Merola makes a strong case for the unfairness of the Section 311 press release process, based on the actions of the bankers and Treasury's failure to issue similar releases for "too big to fail" financial institutions that have admitted money laundering, like HSBC, which paid an almost $2 billion fine. His exposure of the "revolving door" conflicts of interest when government officials get jobs at the companies they once regulated or prosecuted is powerful. But his concluding chapter, tying the 311 designation to the fight for Catalan independence from Spain, is not as well documented. Merola does his best to lay it out in a straightforward, step-by-step manner, but the limited budget and (most likely relatedly) his decision to narrate the film himself evoke the raw aesthetics of YouTube conspiracy videos with mechanical voices. In those cases, the intention is the suggestion of rough authenticity, unmediated by the mainstream media. Placed next to the bonanza of expertly made documentaries available on streaming services, "The Andorra Hustle" is more impressive for its sincerity and good intentions than for its ability to show us exactly who got hustled and how.

Now available on Amazon. 

Nell Minow

Nell Minow is the Contributing Editor at

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Film Credits

The Andorra Hustle movie poster

The Andorra Hustle (2020)


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