Release Date: 19th October 2021
To access the original FCA document, click here.
Summary
Credit Suisse International, Credit Suisse Securities (Europe) Ltd, and Credit Suisse AG (collectively “Credit Suisse”) were fined £147,190,200 by the Financial Conduct Authority (FCA) on 19 October 2021. The fine was imposed due to significant failures in managing financial crime risks related to their Emerging Markets business, particularly in relation to two infrastructure projects in Mozambique involving loans exceeding $1.3 billion. These loans facilitated bribery and corruption, exacerbated by inadequate financial crime controls, due diligence failures, and the acceptance of kickbacks by senior Credit Suisse employees.
Key Takeaways for Firms:
- Strengthen Financial Crime Controls: Ensure robust financial crime strategies are in place, especially in high-risk jurisdictions.
- Holistic Risk Assessment: Evaluate risk factors collectively rather than in isolation.
- Due Diligence: Conduct thorough due diligence on all counterparties, especially in emerging markets.
- Senior Management Oversight: Engage senior management actively in the review and approval processes.
- Transparency and Accountability: Maintain clear and transparent communication with regulatory bodies and adhere to all compliance obligations.
- Independent Verification: Use independent third-party evaluations to verify transactions and mitigate risks.
- React to Red Flags: Take immediate and appropriate action when red flags or allegations of misconduct arise.
In conclusion, the FCA’s action against Credit Suisse underscores the critical importance of rigorous financial crime controls, diligent risk assessment, and robust management oversight. Firms must prioritise these areas to maintain integrity and avoid severe regulatory penalties.
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