bank’s actions ranged from stripping out the word “Iran” from payment messages, to substitutingcode words for Iranian customer names, to hand-checking payment messages from Iran to ensurethat they had been formatted to avoid U.S. sanctions filters. Credit Suisse even advised andtrained the sanctioned entities on how to avoid automated filters at U.S. banks. In essence,evading our banking regulations was a service offered by Credit Suisse to sanctioned countries.As a result, Credit Suisse illegally moved hundreds of millions of dollars through the Americanfinancial system. As part of a deferred prosecution agreement with the Justice Departmentrelating to this conduct, Credit Suisse forfeited $536 million dollars to the government.In each of the cases I just described, the bank’s compliance processes fell far short. Now,I am very aware that at many banks, Bank Secrecy Act and anti-money launderingresponsibilities are considered a cost-center. Setting up an effective compliance program todetect and report suspicious activity means accruing significant expenses for technology,personnel, and training – all without the promise of any short-term profits. But if there is onemessage I want to leave you with today, it is that financial institutions simply cannot cut cornerson compliance: having a compliance program that works is worth it. Indeed, as our recentprosecutions show, failing to adopt and maintain a real compliance structure will have seriousconsequences. Frankly, not having a robust compliance program makes absolutely no businesssense.
Our New Initiatives
Now, more than ever, the American public wants, and deserves, trust and transparencyfrom the financial industry. The public wants to see profits, of course, but not
at the expense of the security of our banks. To that end, I want to talk with you today about two new initiativesthat I believe will significantly enhance the Justice Department’s enforcement efforts. Twoinitiatives that I am proud of.First is the creation of the Money Laundering and Bank Integrity Unit within theCriminal Division’s Asset Forfeiture and Money Laundering Section. The creation of this Unitis a testament to, and builds upon, our recent enforcement successes. The new Unit will bedevoted to investigating complex, national and international criminal cases, and will focus onthree specific types of violators: first, financial institutions, including their officers, managers,and employees, when their actions violate the law; second, professional money launderers whosell their services to criminal organizations; and third, those engaged in using the latest and mostsophisticated money laundering techniques, such as virtual currency and mobile paymentsystems. By standing up this new Unit, we are committing significant resources, and expertise,to prosecuting those who funnel crime proceeds through our banks. Moreover, we are seeking tostaff the Unit with sophisticated, talented and aggressive lawyers – prosecutors and lawyers fromthe banking industry – those who know the complicated mechanisms by which money movesthrough the global financial system, and those who understand how organized criminal networkswork.Our second new initiative is the Kleptocracy Asset Recovery Initiative, which will targetand recover the proceeds of foreign official corruption that have been laundered into or throughthe United States. In November of last year, at the Global Forum on Fighting Corruption and