FCA Issues Lifetime Ban on Three Former Credit Suisse Bankers Over Mozambique Tuna Bonds Scandal

In a landmark enforcement move, the UK Financial Conduct Authority (FCA) has issued lifetime bans against three senior former Credit Suisse bankers—Detelina Subeva, Andrew Pearse, and Surjan Singh—following their criminal convictions in the United States related to the now-notorious Mozambique “tuna bonds” scandal. The FCA’s decision, handed down in May 2025, represents one of the most high-profile actions to date by the UK regulator to hold individual bankers personally accountable for anti-money laundering (AML) failures and breaches of integrity at the highest echelons of global finance.

Central to the FCA’s Final Notice is Detelina Subeva, who served as a Vice President in Credit Suisse’s Global Financing Group. According to the FCA, Subeva “lacks the integrity required to work in UK financial services,” following her admission in a US court that she accepted $200,000 in illicit kickbacks tied to over $1.3 billion in loans arranged for the Republic of Mozambique. The regulator noted that these funds, intended for national development projects, were used as conduits for bribery, corruption, and large-scale money laundering.

The FCA emphasized in its enforcement action that “individuals must uphold integrity, act as stewards of compliance, and report any known or suspected financial crime.” Despite leaving Credit Suisse, Subeva continued her involvement with co-conspirators, the FCA found, “aware of the risk of ongoing corruption.” Her conviction and lifetime prohibition serve as a stern warning to financial professionals regarding the severe consequences of breaching AML obligations.

The Mozambique loan scandal is now regarded as a defining case in the history of international financial crime. Between 2013 and 2016, Credit Suisse and VTB Capital arranged over $2 billion in loans and bonds for Mozambique, purportedly to fund maritime projects such as a state-owned tuna fishing fleet and coastal surveillance. However, investigations later uncovered that hundreds of millions of dollars were funneled into bribes and kickbacks to bankers, middlemen, and Mozambican officials. Much of the money never reached its intended targets, and the loans were deliberately hidden from both Mozambique’s parliament and the International Monetary Fund (IMF).

The consequences were catastrophic. Mozambique defaulted on its sovereign bonds, suffered a massive national debt crisis, and experienced a severe economic downturn. In response, regulators and law enforcement agencies from multiple jurisdictions, including the US Department of Justice (DOJ), the UK’s Serious Fraud Office (SFO), and the Swiss Financial Market Supervisory Authority (FINMA), launched coordinated investigations. The US pursued charges under money laundering laws and the Foreign Corrupt Practices Act (FCPA), while the FCA relied on its powers under the Financial Services and Markets Act 2000 (FSMA) and the Senior Managers and Certification Regime (SM&CR).

Subeva pleaded guilty in the United States District Court for the Eastern District of New York on 20 May 2019 to conspiracy to commit money laundering. Court filings in United States v. Boustani et al., Case No. 1:18-cr-00681, revealed she knowingly accepted and retained $200,000 in illegal payments routed via offshore accounts. This plea formed the basis for the FCA’s decision, which cited not only the criminal conviction but also her continued failure to demonstrate the standards of integrity required in regulated roles.

Andrew Pearse and Surjan Singh, both former Managing Directors at Credit Suisse, faced similar fates. Pearse, who headed the Global Financing Group, admitted to receiving millions of dollars in bribes. Singh was implicated in structuring the controversial transactions and facilitating corrupt payments. The FCA banned both men in February 2025, reinforcing its message that “convictions for serious financial crime overseas will lead to bans and further sanctions in the UK and EU financial markets.”

Beyond the individuals, the FCA previously fined Credit Suisse over £145 million in October 2021 for systemic failings in financial crime due diligence related to the Mozambique transactions. As part of a broader $475 million global settlement, the bank also agreed to cancel $200 million of Mozambique’s debt. The regulatory resolution included penalties from the US Securities and Exchange Commission (SEC) and FINMA, forcing Credit Suisse to confront the reputational and financial damage caused by its compliance failures.

The FCA’s findings and public statements offer a sobering account of the internal failures at Credit Suisse that enabled the scandal. The regulator pointed to a “breakdown of controls,” citing the bank’s inability to perform effective due diligence on borrowers and third-party intermediaries. Basic client vetting and transaction monitoring were “not adequately performed,” and Credit Suisse’s systems failed to detect or act upon numerous red flags, including the opaque structures of the deals and the questionable backgrounds of counterparties.

Testimony and evidence from the US trial revealed a corporate culture in which “commercial incentives overrode compliance red flags.” Employees were discouraged from escalating concerns, and compliance functions were sidelined in favor of closing lucrative deals. This culture of impunity, the FCA concluded, directly contributed to the ease with which corrupt actors manipulated internal systems to commit large-scale financial crimes.

The case also highlights the growing extraterritorial reach of anti-money laundering and anti-corruption regulations. The US DOJ asserted jurisdiction based on the use of US dollars and financial institutions, while the UK leveraged FSMA and SM&CR to enforce accountability. International legal frameworks such as the United Nations Convention against Corruption (UNCAC), ratified by both countries, underpin these cross-border efforts.

For financial institutions and AML compliance officers, the Mozambique affair presents urgent lessons. The FCA reiterated the importance of Enhanced Due Diligence (EDD), especially in high-risk transactions involving complex ownership structures or politically exposed persons (PEPs). Effective AML programs must include “continuous monitoring” throughout the client lifecycle, not just during onboarding. Furthermore, the FCA stressed the importance of whistleblower protection and fostering internal cultures where reporting of misconduct is encouraged and acted upon.

Credit Suisse’s penalties, which included massive regulatory fines and reputational fallout, illustrate the high cost of compliance failures. The bans imposed on Subeva, Pearse, and Singh are not merely symbolic; they represent a clear shift in regulatory expectations toward personal accountability and a zero-tolerance approach to financial crime.

In the wake of these enforcement actions, the FCA’s stance is unequivocal: “Criminal conduct and failure to uphold AML obligations will have lasting consequences.” For professionals in the banking and financial services sector, the Credit Suisse-Mozambique scandal serves as both a cautionary tale and a call to recommit to the principles of integrity, vigilance, and ethical leadership. As regulators around the world continue to tighten their grip on financial misconduct, this case marks a defining moment in the ongoing battle against corruption and money laundering.

By fLEXI tEAM