Sanctions Evasion Reference

Credit Suisse: standard procedures for cover payments

Credit Suisse paid $536 million in 2009 in a global settlement. OFAC found the bank had standard procedures for cover payments and altered messages that hid sanctioned parties across 5,138 transfers.

period

2002–2006

outcome

Settlement

parties

Credit Suisse AG; Credit Suisse Asset Management London; Credit Suisse Securities (USA) LLC

programmes

Islamic Republic of Iran, Sudan, Cuba, Myanmar (Burma), Libya

reviewed

2026-10-04

Cite this page
APA 7 
Sanctions Evasion Reference. (2026, October 4). Credit Suisse: standard procedures for cover payments. https://sanctionsevasion.org/cases/credit-suisse-2009/
Chicago 
Sanctions Evasion Reference. “Credit Suisse: standard procedures for cover payments.” Last reviewed October 4, 2026. https://sanctionsevasion.org/cases/credit-suisse-2009/.
BibTeX 
@misc{ser-cases-credit-suisse-2009,
  author = {{Sanctions Evasion Reference}},
  title  = {Credit Suisse: standard procedures for cover payments},
  year   = {2026},
  note   = {Last reviewed 2026-10-04},
  url    = {https://sanctionsevasion.org/cases/credit-suisse-2009/}
}

The date is when this page was last reviewed, not when it was first published.

Penalties imposed

AuthorityDate AmountNote
OFAC 2009-12-16 $536,000,000 Aggregate amount of a global settlement with OFAC, the Department of Justice and the New York County District Attorney. The funds-transfer apparent violations were not voluntarily self-disclosed; the securities violations were. Total combined base penalty about $1,703,568,000. The Federal Reserve issued a consent cease and desist order.

An early large wire-stripping settlement, and one that says in terms that the practice was a standard procedure.

What OFAC found

OFAC’s web posting for 16 December 2009 states that Credit Suisse “had standard procedures for using cover payments to avoid referencing parties subject to U.S. sanctions and omitting information, removing information, or providing incorrect information in payment messages in order to conceal the identities of U.S. sanctions targets — most notably Iran, Sudan, and Libya.” The payments were for bank and non-bank customers, in electronic funds transfers executed through the United States.

There were two sets of violations:

  • 5,138 funds transfers, August 2003 to December 2006, worth about $644 million, routed through third-party banks in the US. Credit Suisse did not voluntarily self-disclose these.
  • 176 securities transactions, September 2002 to June 2006, worth about $152 million, executed in the US through Credit Suisse Securities (USA) LLC or its predecessor “using code names for the accounts.” They were for a then-designated Libyan state-owned investment company and a bank in Sudan, and the US securities firm did self-disclose them.

The programmes named are Iran, Burma, Sudan, Cuba, Libya and the former Liberian regime.

The settlement

The $536 million is the aggregate for a global settlement among Credit Suisse, OFAC, the Justice Department and the New York County District Attorney. The Federal Reserve separately issued a consent cease and desist order requiring an enhanced global compliance programme, with the Swiss regulator assisting. OFAC calculated a combined base penalty of about $1.7 billion, and mitigated for extensive cooperation (an independent consultant reviewed all incoming and outgoing payment messages for the period), remediation, a clean five-year record, tolling agreements and the agreement to settle.

What the record shows

  • “Standard procedures” is the point. The sanctions result came from how routine payments were handled, not from exceptions. See correspondent banking abuse and wire stripping.
  • Securities were not exempt. The same concealment applied to securities trades through code-named accounts, an early instance of the custody-chain problem on the omnibus securities accounts page.
  • A Swiss bank case. See Switzerland.

Techniques this case demonstrates

Programmes and jurisdictions in this case

  • Iran sanctions — A layered set of US, EU and UN measures dating from 1979 and substantially rebuilt after 2018, covering energy, finance, shipping, and proliferation-related procurement.
  • Sudan sanctions — A US embargo regime from 1997, revoked in 2017 and followed by targeted measures. Its main relevance here is historical: several of the largest penalties in OFAC's record concern conduct from the years it was in force.
  • Cuba sanctions — The oldest US embargo still administered by OFAC: the Cuban Assets Control Regulations of 1963, layered with later statutes, that prohibit most transactions involving Cuba or its nationals unless licensed.
  • Myanmar (Burma) sanctions — The current US programme, built on E.O. 14014 of 2021, blocks the military, the defence and jet fuel sectors, and anyone materially supporting them. OFAC still uses the name Burma.
  • Libya sanctions — A UN regime aimed at armed groups, illicit petroleum exports and the misuse of Libyan state institutions, with a parallel US programme. The Panel of Experts' reporting documents fuel smuggling in unusual detail.
  • Switzerland — A major private banking and securities custody centre whose institutions appear in enforcement records for the same reason as other large financial hubs: they sit between clients and the US financial system.

Enforcement documents and sources

  1. Enforcement action: Credit Suisse AG. U.S. Department of the Treasury, Office of Foreign Assets Control, 2009. Penalty notice, 2009-12-16, US$536,000,000.
  2. Civil Penalties and Enforcement Information. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.

All enforcement cases