Credit Suisse International, Credit Suisse Securities (Europe) Ltd, and Credit Suisse AG
FCA enforcement action, 2021
What failed
Weak financial-crime and anti-bribery controls around opaque loans connected to sovereign debt.
Read the final noticeThe controls that would have caught it
These controls map directly to this failure. Open any one in the Control Builder to set your own thresholds, owners and systems, then export an implementation-ready spec.
In short, the firm needed
- Enhanced due diligence on PEP and sovereign exposures
- Bribery and corruption risk assessment on each deal
- Independent credit and financial-crime sign-off
- Gifts, hospitality and conflicts controls
Enhanced Due Diligence Programme
PreventiveCustomer Due Diligence
For the highest-risk customers, run a deeper, joined-up due diligence package (extra evidence, senior sign-off, closer monitoring) and make sure it actually happens before and during the relationship.
- Starting threshold:
- EDD mandatory on any reg.33 trigger; require 100% of the defined EDD evidence pack complete plus recorded senior approval before activation; enhanced ongoing monitoring with review at least every 12 months (every 6 months for PEPs and the highest-risk band); EDD review more than 30 days overdue is a reportable control breach.
- First-line owner:
- Relationship Management / KYC Operations with EDD specialists
PEP Screening
PreventiveScreening
Flags customers who are senior public officials or their close associates so the firm applies extra checks before and during the relationship.
- Starting threshold:
- Fuzzy match score >= 85% auto-routes to a PEP review queue; matches with corroborating secondary identifiers (DOB, nationality) at >= 80% are also routed for review.
- First-line owner:
- Onboarding / Relationship management
Adverse Media Screening
DetectiveScreening
Searches news and public sources for negative stories about a customer (fraud, corruption, crime) so the firm spots risk that lists alone miss.
- Starting threshold:
- Fuzzy name match >= 85% combined with a financial-crime-relevant category and a credible source auto-routes to review; lower-relevance categories or weak sources are batched for risk-based triage.
- First-line owner:
- Screening Operations / EDD analysts
Typologies behind this case
Related enforcement cases
Next steps
Enforcement data is sourced from the FCA fines dataset. The control mapping is an analyst view of what would have addressed the failings described in the public notice, not a statement of the regulator's findings.