This page describes why a jurisdiction appears in published enforcement records and typology reports. It is not an assessment of the country, its government or its businesses. Every jurisdiction listed here is a substantial legitimate economy, and appearing in this reference is usually a consequence of trade volume and connectivity rather than of weak rules.
Why it appears
Switzerland is one of the world’s largest private banking centres, managing assets for clients across every jurisdiction. That business model means a Swiss bank’s own accounts at US custodians routinely carry positions belonging to many clients at once, which is the structural condition an omnibus account creates regardless of which country’s bank is holding it.
In the record
The EFG case documents a Swiss private bank that settled with OFAC for $3.7 million in 2024: subsidiaries in the Bahamas, Cayman Islands, Luxembourg, Monaco and Switzerland itself processed 873 securities transactions through omnibus accounts at US custodians for clients in Cuba and two designated clients, without those US firms being told who was actually behind the account. The bank’s own internal controls were the only place the underlying clients’ sanctions exposure was known.
See correspondent banking abuse and omnibus securities accounts for how the same structural gap recurs across banking and securities custody.
Two older bank cases
Swiss institutions appear in the earlier wave of bank settlements too. OFAC’s 2009 settlement with Credit Suisse described standard procedures for cover payments and altered messages. In Crédit Agricole’s 2015 settlement, the Swiss subsidiary and its predecessors processed 4,024 of 4,055 Sudan transfers.