Three senior bankers—a former Vice President and two former Managing Directors of Credit Suisse—have been banned for life from working in regulated financial services in the UK. The UK Financial Conduct Authority’s (FCA) landmark decision in May 2025 followed criminal convictions in the United States tied to one of the most notorious financial crime scandals in recent years: the Mozambique “tuna bonds” affair. At the center of the action is Detelina Subeva, whose guilty plea to money laundering, along with the parallel sanctions against Andrew Pearse and Surjan Singh, underscores the FCA’s determination to hold individuals personally accountable for breaches of anti-money laundering obligations and failures in integrity at the highest levels of international banking.

FCA Ban as Evidence of Deep-Rooted AML Weaknesses at Credit Suisse

According to the FCA’s Final Notice, Subeva received $200,000 in illegal kickbacks tied to over $1.3 billion in loans arranged for the Republic of Mozambique. The loans, intended for legitimate projects, became a vehicle for corruption, bribes, and money laundering. The FCA’s findings show that Subeva not only accepted the illicit funds while serving as a regulated vice president but also chose to leave Credit Suisse and continue working with her co-conspirators, aware of the risk of ongoing corruption.

Subeva’s conviction in the US and subsequent prohibition by the FCA is a stark reminder to all financial professionals of the serious consequences of breaching anti-money laundering (AML) obligations. The FCA made it clear that individuals must uphold integrity, act as stewards of compliance, and report any known or suspected financial crime.

How the Mozambique Loan Scandal Became a Landmark AML Case

The Mozambique loan scandal stands as a landmark event in the history of financial crime and regulatory enforcement. In the early 2010s, Mozambique secured over US$2 billion in loans and bonds arranged by Credit Suisse and VTB Capital, purportedly for maritime projects such as a state tuna fishery and coastal protection.

While the official purpose was to finance the country’s economic development, significant portions of the funds were siphoned off through bribes and kickbacks to bankers, intermediaries, and Mozambican officials. Investigations later revealed that much of the money never reached its intended projects, and the loans were concealed from the International Monetary Fund (IMF) and Mozambique’s own parliament.

The resulting financial hole contributed to a national debt crisis, led to defaults on sovereign bonds, and plunged Mozambique into economic turmoil.

Regulatory and Legal Responses

Authorities in multiple jurisdictions responded forcefully. US federal prosecutors charged several individuals, including Subeva, Pearse, and Singh, with money laundering and wire fraud. The US Department of Justice (DOJ) and the UK’s Serious Fraud Office (SFO) coordinated with other regulators, such as the FCA, to pursue both criminal and civil penalties.

On 20 May 2019, Detelina Subeva pleaded guilty before a US court to conspiracy to commit money laundering, admitting she accepted and retained $200,000 in illegal kickbacks related to the Mozambique loans. The US case demonstrated the reach of American anti-corruption laws under statutes like the Foreign Corrupt Practices Act (FCPA) and money laundering provisions in 18 U.S.C. § 1956.

Back in the UK, the FCA leveraged its powers under the Financial Services and Markets Act 2000 (FSMA) to pursue regulatory enforcement. In October 2021, the FCA fined Credit Suisse over £145 million for serious failings in financial crime due diligence. The bank, as part of a $475 million global settlement (also involving US and Swiss regulators), also agreed to write off $200 million of Mozambique’s debt, acknowledging the tainted nature of the underlying transactions.

Financial Crime, AML Failures, and the Ripple Effects

The events that led to the FCA’s ban on Subeva are symptomatic of deeper problems in the design and enforcement of AML frameworks at global banks.

Breakdown of Controls

The Credit Suisse case exposed how sophisticated actors could bypass traditional compliance checks:

• Failure of Due Diligence: Internal documentation and investigations confirmed that Credit Suisse failed to conduct effective due diligence on the borrowers and the complex web of intermediaries involved. The FCA highlighted that basic steps such as proper vetting of clients and ongoing transaction monitoring were not adequately performed.
• Third-Party Risks: The use of opaque intermediaries allowed for the layering of bribes and kickbacks, making it easier to disguise the proceeds of corruption. Credit Suisse’s systems did not detect red flags related to the structure of the deals or the backgrounds of counterparties.
• Culture and Accountability: The bank’s commercial incentives overrode compliance red flags. Testimonies in US and UK proceedings revealed a culture where the drive for deal-making overshadowed ethical responsibilities and internal escalation of concerns.

Legal and Regulatory Frameworks

This case demonstrates the broad extraterritorial reach of AML and anti-corruption regulations. The US DOJ asserted jurisdiction based on US dollar transactions and US-linked entities. The FCA’s powers stem from the Financial Services and Markets Act 2000 and the Senior Managers and Certification Regime (SM&CR), which hold individuals personally accountable for compliance failures.

Moreover, the United Nations Convention against Corruption (UNCAC), ratified by both the US and UK, establishes international standards for criminalizing bribery and enhancing international cooperation on money laundering cases.

The Individual Cases: Subeva, Pearse, and Singh

Detelina Subeva

As vice president at Credit Suisse’s Global Financing Group, Subeva played a central role in arranging the Mozambique loans. According to US court records (Eastern District of New York, United States v. Boustani et al., Case No. 1:18-cr-00681), Subeva admitted to knowingly accepting $200,000 in illegal kickbacks routed via offshore accounts.

Her guilty plea led to her being sentenced in the United States, with the FCA later concluding she “lacks the integrity required to work in UK financial services.” This enforcement action reflects the FCA’s statutory objective to protect and enhance the integrity of the UK’s financial system.

Andrew Pearse and Surjan Singh

Andrew Pearse and Surjan Singh, also former Credit Suisse executives, were previously convicted in the US for related conduct. Pearse, who led Credit Suisse’s Global Financing Group, admitted to taking millions in bribes and kickbacks, while Singh played a supporting role in structuring deals and facilitating payments. Both were banned by the FCA in February 2025.

Collectively, these actions by the FCA reinforce the message that convictions for serious financial crime overseas will lead to bans and further sanctions in the UK and EU financial markets.

What This Means for AML Compliance Officers and Financial Institutions

The Mozambique loans affair highlights critical lessons for compliance professionals, especially those working in AML, anti-bribery, and corruption prevention.

Importance of Personal Accountability

Under the FCA’s Senior Managers and Certification Regime (SM&CR), senior executives and key personnel are required to demonstrate integrity and competence. The regime emphasizes individual accountability and the duty to prevent financial crime. The FCA’s action against Subeva illustrates that failure to uphold these standards, even in the context of foreign convictions, can result in a lifetime ban from the industry.

Cross-Border Enforcement and Cooperation

The joint investigations and coordinated enforcement between US, UK, and Swiss authorities demonstrate that financial crime is a truly global concern. Regulatory frameworks such as the EU’s Sixth Anti-Money Laundering Directive (6AMLD) and the UK’s Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 impose stringent obligations on firms to detect, prevent, and report suspicious activities.

Risk of Reputational and Financial Loss

Credit Suisse’s penalties—over £145 million from the FCA alone, plus the write-off of $200 million of Mozambique’s debt—underscore the immense financial and reputational risks posed by AML failures. The global settlement, which also included penalties from the US Securities and Exchange Commission (SEC) and Swiss Financial Market Supervisory Authority (FINMA), forced the bank to acknowledge the broad consequences of its compliance lapses.

Practical Lessons for AML Programs

Key takeaways for financial institutions and AML officers include:

• Enhanced Due Diligence (EDD): High-risk transactions and clients require robust due diligence that goes beyond checklists and standard reviews. Deep analysis of beneficial ownership, source of funds, and the legitimacy of complex structures is vital.
• Continuous Monitoring: AML compliance must include not just onboarding checks but ongoing scrutiny throughout the client relationship and transaction lifecycle.
• Whistleblower Protections: Encouraging internal reporting of suspicious conduct is essential. Regulatory bodies are increasingly willing to reward and protect whistleblowers who expose financial crime.

Conclusion: The Enduring Impact of the FCA’s Ban

The FCA’s decision to ban Detelina Subeva for her role in the Mozambique loan scandal sends a clear message to financial institutions and their employees: criminal conduct and failure to uphold AML obligations will have lasting consequences. The FCA’s use of its regulatory powers is not just symbolic. It is part of a broader trend toward increasing personal accountability, cross-border cooperation, and tough enforcement in the fight against financial crime.

For AML and compliance professionals, the case serves as a reminder of the importance of vigilance, the need to challenge questionable deals, and the imperative to foster a culture of integrity and transparency. As global regulators continue to tighten the net on money laundering and corruption, the Credit Suisse case stands as both a cautionary tale and a guidepost for best practices. imperative to foster a culture of integrity and transparency. As global regulators continue to tighten the net on money laundering and corruption, the Credit Suisse case stands as both a cautionary tale and a guidepost for best practices.

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Related Links

• FCA Press Release on Detelina Subeva Ban
• US Department of Justice: Mozambique Loan Scandal Prosecutions
• UN Convention against Corruption (UNCAC)
• EU Sixth Anti-Money Laundering Directive (6AMLD)
• The 3 FCA Final Notices: Detelina Subeva, Andrew James Pearse, Surjan Singh

Other FinCrime Central News About Credit Suisse Failures

• Swiss Prosecutor Rocks Credit Suisse Acquittal in Landmark Money Laundering Appeal
• Credit Suisse Hit with $511M U.S. Tax Evasion Penalty
• Ex-Credit Suisse Executive Fined CHF 100,000 for Money Laundering Role in Mozambique Scandal

Source: FCA

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