Financial Crime World

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Swiss Authorities Proceed Against Former Officials and Unknown Individuals in Multi-Million Dollar Bribery Scheme

Investigation Launched

Geneva, Switzerland - The Office of the Attorney General (OAG) has launched proceedings against two former officials at 1MDB and unknown individuals suspected of:

  • Bribing foreign public officials
  • Misconduct in public office
  • Money laundering
  • Criminal mismanagement

The investigation began in April 2016 and was extended to include two former officials who were in charge of Abu Dhabi sovereign funds. They are accused of:

  • Fraud
  • Criminal mismanagement
  • Misconduct in public office
  • Document forgery
  • Bribery of foreign public officials
  • Money laundering

Convictions and Fines

In a separate case, the OAG convicted Brazilian company Odebrecht SA and its subsidiary Braskem in December 2016 for:

  • Organisational failure to prevent bribery of foreign officials
  • Money laundering

The company was fined 4.5 million Swiss francs and ordered to disgorge profits of over 200 million Swiss francs.

Follow-Up Probes

The investigations have led to a number of follow-up probes, including cases against individuals suspected of involvement in the Petrobras/Lava Jato scandal. One banker in Brazil has already been charged in connection with the case.

In another notable development, the OAG settled a case involving a company that reported suspicious activity related to bribery of foreign officials. The company was fined a symbolic amount of one Swiss franc and ordered to disgorge profits of 35 million Swiss francs.

Importance of Risk and Compliance Management

These cases highlight the importance of risk and compliance management in preventing corporate criminal liability. Swiss state-owned companies, including those in the public sector, are required to employ best practice risk and compliance management systems to avoid criminal liability.

Government Obligations

Swiss government agencies and state-owned enterprises are required to conduct themselves in accordance with the statutes under which they were established. This includes meeting compliance obligations and avoiding criminal liability in the event of employee misconduct.

Digital Transformation

The Swiss government has introduced a framework covering digital transformation, which outlines key statutory and regulatory differences between public sector and private sector risk and compliance management obligations.

Corporate Switzerland is facing a series of crises due to increasing regulation and tighter controls by the authorities. The OAG has launched numerous investigations into suspected bribery and money laundering cases involving Swiss and foreign companies.

International cooperation has also been stepped up, with Switzerland working closely with other countries including Brazil, France, Germany, Greece, Italy, the Netherlands, Spain, and the United States to combat corporate crime.

Law Stated Date

Correct as of [insert date].

Unprocessed Questions

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