Credit Suisse Responds

In response to requests for comment by OCCRP, Süddeutsche Zeitung, The Guardian, and other media outlets, Credit Suisse sent the following official statement:

Credit Suisse strongly rejects the allegations and inferences about the bank’s purported business practices. The matters presented are predominantly historical, in some cases dating back as far as the 1960s, including at a time where laws, practices and expectations of financial institutions were very different from where they are now. Furthermore, the accounts of these matters are based on partial, selective information taken out of context, resulting in tendentious interpretations of the bank’s business conduct. While Credit Suisse cannot comment on potential client relationships, we can confirm that actions have been taken in line with applicable policies and regulatory requirements at the relevant times, and that related issues have already been addressed.

As a leading global financial institution, Credit Suisse is deeply aware of its responsibility to clients, and the financial system as a whole to ensure that the highest standards of conduct are upheld. These media allegations appear to be a concerted effort to discredit the bank and the Swiss financial marketplace, which has undergone significant changes over the last several years. In line with financial reforms across the sector and in Switzerland, Credit Suisse has taken a series of significant additional measures over the last decade, including considerable further investments in combating financial crime. Across the bank, Credit Suisse continues to strengthen its compliance and control framework, and as we have made clear, our strategy puts risk management at the very core of our business.

The bank refused to comment on any specific matters relating to clients, or to confirm or deny a customer relationship with any of the individuals appearing in the data held by journalists. However, it made the following points in response to questions asked by OCCRP and partners.

• We have reviewed the matters raised.
• Many allegations are historic, ranging from the 1960s onwards, and were subject to reviews in the past decades in line with applicable processes and requirements at the relevant times.
• An overwhelming majority of the reviewed accounts are today closed or were in the process of closure prior to receipt of the press inquiries, with closures covering a 38-year period, of which the majority were closed before 2015.
• Of the remaining active accounts we are comfortable that appropriate due diligence, reviews and other control related steps were taken.
• We will continue to analyze the matters and take additional steps if necessary.

Tax Compliance

• Credit Suisse has a strict zero tolerance policy towards tax evasion and is fully committed to complying with global tax transparency efforts including the Foreign Account Tax Compliance Act (FATCA) and the Automatic Exchange of Information (AEI).
• Internal directives and conduct requirements strictly prohibit Credit Suisse personnel to assist clients or other third parties to evade taxes or to circumvent tax disclosure regimes such as FATCA and AEI.
• Credit Suisse only wishes to deal with clients who are tax compliant. Over the past decade, the bank has implemented numerous client tax compliance programs spanning multiple jurisdictions across Europe, Asia, the Middle East and South America. Credit Suisse has consequently ended business dealings with clients who did not participate in our client tax programs.
• Further, the bank has established a robust client tax framework to manage client tax evasion risk. On top of our strong commitment to FATCA and AEI reporting, wealth planning structures such as trusts are required to provide documentation of tax compliance at account opening.

Preventing Money Laundering

• Credit Suisse has stringent control mechanisms in place to combat financial crime-related activities. These controls are designed to prevent the exposure of Credit Suisse and its clients to the risks of specific and systematic money laundering.
• Credit Suisse conducts name screening in line with industry standards to identify and manage financial, regulatory and reputational risk, both at onboarding as well as in relation to existing accounts.
• In the circumstances where we identify any relationships which could have been used for such purposes or other illicit activity, we take prompt and decisive action which will include liaison with applicable authorities and restrictions of activity up until and including termination in line with respective regulatory requirements.
• For private company accounts, where the account holder is not the beneficial owner of the assets (e.g., structures), evidence has to be provided with regard to the identity of third-party beneficial owners holding interests in such account above minimum regulatory thresholds, subject to applicable AML laws.

Risk Management

• In November 2021, Credit Suisse announced its Group Strategy placing risk management at the very core of the bank.
• In 2021, we completed a full-scale risk review across the entire bank, recalibrating the risk appetite at both Group and divisional levels and strengthening the risk management leadership and oversight at the BoD level.
• The following initiatives have already been completed or are underway:
  • Fundamental risk review, examining how risks are being assessed, managed and controlled across the Group.
  • Clear definition of roles, responsibilities and accountabilities across all divisions, as Credit Suisse continues to implement remediation efforts that were initiated earlier last year (2021).
  • Development of tools and processes to improve business accountability and ownership as the first line of defense for risk and controls.
  • Revision of compensation process and structure, incorporating risk-sensitive performance and non-financial objectives into the enhanced performance scorecards.
  • Fostering a culture that reinforces the importance of personal accountability and responsibility.
• As part of the outcomes of the strategic review, the bank will continue to focus on risk culture, putting risk management at the heart of all its actions, with investments in data, infrastructure, reporting capabilities, as well as in compliance.