Loans to Mozambican state-owned companies: Office of the Attorney General of Switzerland indicts Credit Suisse on charges of money laundering and organisational deficiencies

The commercial relationship concerned was connected with loans worth over USD 2 billion which the Credit Suisse financial group granted in 2013 to three Mozambican state-owned companies in transactions which in 2016 became known as the ‘Mozambique Debt Scandal’. In 2020 the OAG opened initial criminal proceedings in this connection, which it is currently conducting against two natural persons on suspicion of money laundering (Art. 305^bis Swiss Criminal Code, SCC) and complicity in the bribery of foreign public officials (Art. 25 in conjunction with Art. 322^septies SCC). Based on the findings from these initial criminal proceedings, the OAG opened a second criminal investigation in 2023, which it has now concluded by filing the indictment on 25 November 2025.

Criminal origin of the transferred funds

The case focuses on a commercial relationship between CS and a foreign company purported to be active in management consultancy and asset management and suspected of being involved in the events surrounding the “Mozambique Debt Scandal”. In the spring of 2016, funds amounting to around USD 7.86 million were transferred from Mozambique’s Ministry of Economy and Finance to accounts held by this company at CS in Switzerland.

The funds received by CS from Mozambique are presumed to have originated from a so-called ‘running fee’ agreed between the account holder and Mozambican state-owned companies, which was state guaranteed and paid for alleged services in connection with the aforementioned loans. According to the indictment, the money received from Mozambique, i.e. the running fee, was obtained or facilitated through offences committed in Mozambique, in particular through corruption (bribery of Mozambican public officials) and misconduct in public office in Mozambique.

Compliance officer indicted on charge of money laundering

A short time after the money was credited, the account holder transferred USD 7 million of the funds received to bank accounts in the United Arab Emirates. In response to this bank transfer, CS began enquiries into the commercial relationship in question. The compliance officer at CS who has now been indicted was apparently instrumental in conducting these enquiries. The indictment states that although she was aware of numerous indications that the funds received from Mozambique could be of felonious origin, she recommended that the management board of CS and the Credit Suisse Group should not file a report to the Money Laundering Reporting Office Switzerland (MROS), but instead terminate the commercial relationship.

In the course of the termination of the relationship in autumn 2016, the funds remaining at CS that originated from suspected offences in Mozambique, which amounted to around USD 609,000 and CHF 28,000, were transferred to accounts abroad.

According to the indictment, the OAG alleges that, by recommending the termination of the commercial relationship and by being negligent in carrying out the money laundering investigation assigned to her. The accused compliance officer caused or permitted the remaining funds that were suspected to be felonious origin to be moved abroad and thereby to be laundered. As a consequence, the OAG has charged the compliance officer with money laundering under Article 305^bis number 1 SCC.

Inadequate organisation at CS and in the Credit Suisse Group

It was not until 2019 that CS or the Credit Suisse Group filed a report of suspected money laundering with MROS, after the US Department of Justice (DOJ) had announced that it was conducting criminal proceedings in connection with the Mozambique loan transactions.

CS and the Credit Suisse Group – or their successor companies UBS SA and UBS Group SA, which took over CS and the Credit Suisse Group respectively in June 2023 – have been charged by the OAG with not taking all the required and reasonable organisational measures in the relevant period in 2016 to prevent the money laundering that was allegedly committed. According to the indictment, in 2016 in particular considerable defects existed in the companies’ risk management, compliance and internal directives systems in connection with combating money laundering. In particular, the indictment states that the aforementioned money laundering investigation was conducted with a lack of due care and the bank was too late in reporting a suspicious transaction to MROS. UBS SA and the UBS Group SA are therefore charged as companies with being criminally liable under Article 102 SCC in conjunction with Article 305^bis SCC for the money laundering believed to have been committed.

Proceedings against a further defendant abandoned

In an order dated 25 November 2025, the OAG abandoned the criminal proceedings against a further defendant employed by CS and the Credit Suisse Group. In the period in which the offences were committed, this defendant was responsible for the Compliance Unit as well as being a member of the management board of CS and the Credit Suisse Group and involved in the aforementioned money laundering investigation.

In March 2025, the Federal Department of Finance (FDF) convicted the defendant in separate administrative criminal law proceedings conducted in connection with the Mozambique loans for a violation of the duty to report (in accordance with Art. 37 para. 1 in conjunction with Art. 9 para. 1 Anti-Money Laundering Act, AMLA). This conviction is currently the subject of an appeal to the Federal Criminal Court and is not yet legally binding.

As the allegations against the defendants in the FDF proceedings are largely based on the same factual circumstances as those in the proceedings conducted by the OAG, the OAG concluded that an additional parallel prosecution was neither objectively warranted nor appropriate in the interests of procedural economy. As a result, the OAG abandoned its criminal proceedings against the second defendant for reasons of procedural economy (Art. 319 para. 1 let. e Swiss Criminal Procedure Code, CrimPC).

As soon as the ruling abandoning proceedings becomes legally binding, a copy may be requested or may be inspected in anonymised form at the Legal Services Section of the Office of the Attorney General of Switzerland: rechtsdienst@ba.admin.ch.

From now on, the Federal Criminal Court is responsible providing the media with information on this case. As is customary, the OAG will give notice of its sentencing proposals during the hearing. Finally, it should be noted at this point that the presumption of innocence continues to apply until a final judgment has been issued.