FINMA Credit Suisse FIFA Failings

On Sep. 17, FINMA announced Credit Suisse AML failure re FIFA.

  • Announced the conclusion of two investigations into AML failings at Credit Suisse.


  • An investigation identified deficiencies in anti-money laundering due diligence, re suspected corruption involving FIFA, Petrobras, Petróleos de Venezuela (PDVSA).
  • Second re significant business relationship with politically exposed person (PEP).
  • Deficiencies in AML process and bank's control mechanism and risk management.
  • Ordered measures to improve AML, speed up implementing steps already initiated.
  • Will commission independent third party to monitor implementation, effectiveness.

FIFA, Petrobras, PDVSA

  • Shortcomings in identifying client, determining the beneficial owner, categorizing relationship as posing increased risk, clarifications, plausibility check, documents.
  • Shortcomings occurred repeatedly over a number of years, mainly before 2014.
  • Above-average faults in relationships opened by former subsidiary Clariden Leu.
  • The bank still has no automated comprehensive overview of client relationships.
  • Credit Suisse has been in process of implementing single client view since 2015.
  • Progress has been made, but still to be extended outside the Compliance unit.

Politically Exposed Person

  • FINMA initiated enforcement proceedings in 2016 and appointed an investigator.
  • Bank was too slow to identify and treat the PEP client as posing increased risks.
  • Due diligence and corresponding documentation re relationship were incomplete.
  • Failed to meet heightened due diligence obligations re investigation, plausibility
    checks and documentation reg client and certain related high-risk transactions.
  • Bank failed to adequately record, contain, monitor the risks arising from the PEP
    relationship and responsible (criminally convicted) client relationship manager.
  • Relationship manager was very successful in terms of assets under management.
  • Manager breached the bank's compliance regulations repeatedly and on record.
  • Instead of disciplining, bank rewarded with high payments, positive assessment.
  • Identified organisational deficiencies and lack of effective corrective intervention.

Measures to Strengthen AML

  • Bank has addressed situation and adopted several measures since the end 2015
    to strengthen its compliance in general and so as to combat money laundering.
  • Cooperated with FINMA, which acknowledges improvements, some substantial.
  • However, it has decreed additional measures to complement the bank’s actions.
  • Designed to further improve bank’s governance, organisation, risk management.
  • Remediate relevant control systems, processes, prove higher-risk relationships,
    transactions are adequately detected, categorized, monitored and documented.
  • Must implement single client view for all relationships, functions by end 2019.