The Tuna Bonds Scandal: A Case Study in Global Financial Crime

The ‘Tuna Bonds’ scandal which linked Credit Suisse and Mozambique has become a textbook case in how financial crime and poor risk management can spiral out of control. It shows how unchecked corruption, money laundering, and major failings in the global banking system can trigger a full-blown financial crisis.

Between 2013 and 2016, Mozambique had secretly borrowed over $2 billion. These loans were meant to boost the economy by funding maritime projects, like a tuna fishing fleet. But instead, the funds vanished into a web of bribery, embezzlement, and fraud.

🧭 Overview

• Period: 2013–2016
• Key Players: Credit Suisse, VTB (Russia), Mozambican officials, Privinvest
• Purpose: Fund economic development via maritime infrastructure
• Outcome: Triggered a sovereign debt default and a severe economic crisis

⚙️ The Mechanisms of Financial Crime

1. Secretive Loan Agreements
   The concealment of over $1 billion in loans arranged by Credit Suisse for Mozambican state-owned enterprises are an example of what poor compliance can result in. In this case, these loans were hidden from both the IMF and Mozambique’s parliament. This resulted in widespread money laundering and the embezzlement of funds.
2. Bribery and Kickbacks
   More than $200 million in bribes were paid, to the following:

• The politically elite population, public officials, and bankers.
• The Credit Suisse staff themselves.
• The executives at intermediary firms.

These funds were moved via shell companies and offshore accounts, which successfully evaded KYC checks, PEP screening, and enhanced due diligence (EDD) protocols.

3. Inflated Contracts and Fake Invoicing

An example of this was the identification of Privinvest had been found to have generated inflated contracts and issued fake invoices to clientele. This was critical in enabling the diversion of funds and production of illicit payouts. These are classic examples of AML red flags appearing due to the lack of robust KYC verification and AML investigations checkpoints.

4. Use of Offshore Jurisdictions
   The stolen funds were identified to have been routed out of the KYC compliance surveillance through the following ways:

• Deposited in multiple financial secrecy havens.
• Shell corporations
• Through the generation of false documentation
  This layering tactic is common in sophisticated money laundering schemes designed to bypass regulatory systems and financial intelligence units (FIUs).

🧾 Legal Fallout

As a result, Mozambique defaulted on its debt, leading to public unrest. Credit Suisse paid over $475 million in fines and had to settle $22.6 million with investors in 2023. This led to police arrests across banks, state offices, and intermediaries. This then prompted to regulators launched audits and demanded major reforms—many involving risk consultants and compliance frameworks.

🔍 AML Analysis and Failures

1. Inadequate Due Diligence.
   Credit Suisse had failed to perform EDD on high-risk clients and PEPs which violated standard AML compliance protocols.
2. Deficient Transaction Monitoring
   The bank failed to identify clear red flags such as:

• Large across the border transfers.
• Illegitimate offshore accounts.
• Unregulated over-invoicing.

The poor use of AI-driven transaction monitoring, KYC analytics, and risk monitoring tools made it worse.

3. Lack of Risk-Based Approach
   Institutions ignored the FATF’s risk-based approach and approved high-risk sovereign transactions without proper customer risk profiling, AML onboarding, or KYC validation. Allowing for illegal transactions to slip through.
4. Compliance Culture and Governance Failures
   The scandal revealed weak compliance culture which included sidelined AML teams, and poor internal controls. This also highlighted the lack of compliance training and misaligned governance systems which made financial institutions vulnerable.
5. Misuse of Complex Structures
   The funds moved through UBO-masked shell companies and layered offshore structures. With poor KYC onboarding and beneficial ownership verification this led to the money laundering going undetected.

🇲🇿 Key Takeaways

This scandal is a prime example of state-linked money laundering and financial crime. It shows how poor governance and lax compliance controls in international banking create space for corruption.

Urgent needs include:

• Stronger internal governance and AML culture
• Consistent EDD, risk-based approaches, and transaction monitoring
• Tighter oversight of sovereign lending
• Greater collaboration among financial institutions, regulators, and compliance consultants
• Adoption of AI assurance tools, fraud detection analytics, and KYC remediation
• Expanded use of compliance audits, customer due diligence, AML policies, and data-driven fraud detection