Not being able to impose monetary penalties, Swiss financial supervisor FINMA concluded two enforcement procedures against Credit Suisse AG. In the first, FINMA identified wide-ranging deficiencies in the bank’s AML program in three of the biggest global fraud/AML cases of the past ten years: the International Federation of Association Football (FIFA) scandal, Brazil’s oil corruption case involving Petrobras, and Venezuelan oil bribery and corruption case involving Petróleos de Venezuela, S.A. (PDVSA). The second procedure was a garden-variety PEP versus high-performing Relationship Manager case. Collectively, FINMA “decreed measures to further improve anti-money laundering processes and to accelerate the implementation of steps already initiated by the bank” and, notably, FINMA imposed “an independent third party to monitor the implementation and effectiveness of these measures.”
One of the most significant findings – and a warning to financial institutions everywhere – was that there was “no automated comprehensive overview of client relationships”. FINMA found:
“To combat money laundering effectively, every relevant department within the bank must be able to see all the client’s relationships with the bank instantly and automatically. Credit Suisse AG has been in the process of implementing such a “single client view” since 2015. Progress has been made, however this overview is still to be extended outside the Compliance unit. This results in organisational weaknesses in addition to the contraventions of anti-money laundering provisions.”
The result? Credit Suisse will need to build out a real-time, bank-wide single view of the customer … or Enterprise View of the Customer (EVOC).