Credit Suisse's Money Laundering Conviction Came Down to One Employee. When She Died, So Did the Case.

Issue #19 | September 1, 2026 | 7 min read

In June 2022, a Swiss court did something no Swiss court had ever done: it criminally convicted a major bank of money laundering. Credit Suisse had banked a Bulgarian cocaine trafficker's network for years, and a relationship manager who handled the accounts was convicted alongside it. Two years later, that relationship manager was dead, and so, on appeal, was the conviction.

This issue covers how the case was built, what it took to convict a bank that had never faced criminal charges before, and why the whole thing came apart on a legal technicality that had nothing to do with whether the money was dirty.

The underlying facts were never seriously in dispute. The bank's guilt collapsed anyway, for a reason no compliance program could have prevented.

Between 2004 and 2008, Credit Suisse's Zurich private bank handled accounts tied to Evelin Banev, a Bulgarian former wrestler who ran a cocaine-trafficking network moving product into Europe. The relationship manager on those accounts, Elena Pampoulova-Bergomi, a Bulgarian former tennis player, kept the business running even as the bank's own compliance function documented what Swiss prosecutors would later describe as concrete suspicions about where the money came from. Roughly CHF 146 million moved through those accounts before anyone outside the bank stopped it.

Swiss federal prosecutors indicted Credit Suisse in December 2020, the first time a major Swiss bank had faced criminal charges over money laundering in the country's history. The trial opened in February 2022 at the Federal Criminal Court in Bellinzona. On June 27, 2022, the court convicted both Credit Suisse and Pampoulova-Bergomi. She got 20 months. The bank got a fine that looked almost like an afterthought next to what came with it.

The CHF 2 million fine was the headline number, but it wasn't the real penalty. The court also ordered the confiscation of more than CHF 12 million still sitting in the trafficking network's Credit Suisse accounts, and ordered the bank to pay a further CHF 19 million in compensation for funds that had already left the bank and couldn't be recovered, specifically because of gaps in the bank's own internal controls. Add it up and the bank's actual exposure ran past CHF 33 million on a case built around a CHF 2 million fine.

Then the case that made history started unmaking itself. Credit Suisse collapsed entirely in March 2023, in a crisis that had nothing to do with this conviction, and UBS absorbed it in an emergency acquisition. A month later, Pampoulova-Bergomi died following a long illness. Her heirs and the bank, now standing as UBS, both appealed. On November 27, 2024, the Federal Criminal Court's appeals chamber acquitted UBS of the corporate money-laundering charge entirely, and lifted the compensation order along with it. The reasoning wasn't that the money wasn't dirty, or that the original court got the facts wrong. It was that Pampoulova-Bergomi had died before her own appeal could be heard, and a court can't affirm a dead defendant's guilt without violating her presumption of innocence. Switzerland's corporate liability statute ties a bank's conviction to establishing that a specific individual committed the underlying offense. Once her guilt could no longer be finalized, the bank's conviction had nothing left to stand on.

Swiss prosecutors aren't done. In March 2025, the Office of the Attorney General appealed straight to the Federal Supreme Court, asking for the conviction back. UBS filed its own cross-appeal, arguing separately that a bank shouldn't inherit a predecessor's criminal liability through a merger at all, an argument the Federal Criminal Court had already rejected once, on the grounds that UBS's own acquisition agreement transferred Credit Suisse's legal standing in every pending proceeding. In March 2026, the appeals chamber confirmed the acquittal again.

Red flags in this case

If you work in AML risk assessment on the M&A side, the UBS half of this story matters more than the Bulgarian cocaine ring does. UBS didn't create this exposure. It inherited it, by contract, the moment the acquisition agreement transferred Credit Suisse's legal standing in every pending case. Treat a target institution's open criminal and regulatory proceedings as a liability that survives closing, not one that resets with the merger.

And if you work anywhere that ties institutional accountability to a single named individual, sit with what actually happened here. Nobody argued the money was clean. Nobody argued the original verdict got the facts wrong. A court had already confiscated the funds it could find and ordered the bank to cover what it couldn't. None of that mattered once the one employee whose guilt the corporate charge depended on didn't live long enough to lose her own appeal. Institutional liability built on a single individual's conviction is only as durable as that individual's ability to be tried to a final judgment.

Credit Suisse's own account records showed CHF 146 million moving for a cocaine trafficker's network, and a court convicted the bank of it. Four years later, an employee's death gave that conviction nowhere left to stand.

Source: Federal Criminal Court of Switzerland (Bellinzona), judgment convicting Credit Suisse and Elena Pampoulova-Bergomi, June 27, 2022 | Federal Criminal Court, appeals chamber ruling acquitting UBS, November 27, 2024 | Reuters/SWI swissinfo.ch, reporting on the Office of the Attorney General's March 2025 Federal Supreme Court appeal and the appeals chamber's March 2026 confirmation of the acquittal | OCCRP, reporting on the underlying Banev trafficking network

Treasury/OFAC — On August 20, Treasury designated 15 Ecuador-based targets and blocked 10 vessels operating under the cover of legitimate fishing businesses, used to move thousands of kilograms of cocaine a month from Ecuador toward Mexico for distribution in the United States. The network is tied to Los Choneros and Los Lobos, two Ecuadorian gangs designated as Foreign Terrorist Organizations, which feed cocaine to the Sinaloa Cartel and CJNG for smuggling across the U.S. border. Source: U.S. Department of the Treasury, "Treasury Sanctions Major Ecuador-Based Cocaine Network Linked to Violent Gangs and Mexican Cartels," August 20, 2026.

DOJ — On August 26, federal prosecutors charged Christopher A. Bravo Marin, an employee of a Minnesota-based money transmitter, with conspiring to launder at least $750,000 in drug proceeds for CJNG. Prosecutors allege he used his knowledge of his own employer's compliance procedures against it: forged signatures, fake names, and transfers kept just under the $1,000 threshold that would have triggered identification requirements. He was allegedly paid $40 to $50 per transfer. Source: DOJ, "Operator of Minnesota-Based Money Transmitter Charged With Laundering Drug Proceeds for Mexican Cartel Following Homeland Security Task Force Investigation," August 26, 2026.

Private banking relationship managers occupy an odd seat: paid to bring in and retain large clients, and also supposed to be the first line of defense against the client whose business would be most lucrative to keep. BLS folds this work mostly into Personal Financial Advisors, where the median wage hit $102,140 in May 2024, well above line-level compliance pay. That premium exists because the role carries a conflict this issue's case put on full public display. Worth naming to yourself before you take a book of clients, not after a monitoring alert lands on your desk with one of their names on it.

In partnership with Artha. If you apply through a listing below, we may earn a commission at no cost to you. We only pick roles we'd tell a colleague to apply for.

Got any idea for something you'd want to see covered here? Doesn't have to fit neatly into a category. If you think it's interesting, we probably will too.

Send it to [email protected].

If someone forwarded this to you, welcome.

The AML Brief goes out every Tuesday. Subscribe for free and get the Top 10 AML Red Flags cheat sheet as a thank-you:

[BUTTON: Subscribe → theamlbrief.com]

Already subscribed? Forward this to one colleague who works in financial crimes. That's how we grow.

The AML Brief | theamlbrief.com

Disclaimer: The AML Brief is an independent financial crimes intelligence publication. All content is sourced from publicly available regulatory documents, enforcement actions, and published research. Nothing published here constitutes legal, compliance, or regulatory advice. The AML Brief is not affiliated with any financial institution, regulator, law firm, or employer. For advice specific to your situation, consult a qualified attorney or compliance professional.