The case involves funds linked to loans to Mozambican state-owned companies. Despite multiple indicators suggesting criminal origin, the bank terminated the client relationship and transferred remaining funds abroad without filing a suspicious transaction report to MLROs.
Key lessons for compliance professionals:
• Offboarding a client does not remove the duty to file a Suspicious Activity Report.
• Compliance Officers may face personal liability for AML negligence.
• Weak governance and escalation processes can amount to organisational AML deficiencies.
• Institutions must ensure that end-of-relationship procedures do not enable the movement of illicit funds.
• A strong AML framework must operate consistently across onboarding, monitoring and termination.
This case underscores a fundamental principle:
AML failures are often governance failures — and regulators are increasingly holding both institutions and individuals accountable.
For more details, see the official communication from the Office of the Attorney General of Switzerland:
https://www.bundesanwaltschaft.ch/en/newnsb/4gw8CbcWrf9y9WTv8r_Up
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