A case: the suspicious activity report seen from the inside

Worked example. The head of compliance of a Geneva bank receives an alert on an account held by a company in the Emirates whose beneficial owner is a national of a West African country. Within three months the account has received USD 4.2 million from three trading companies and transferred USD 3.9 million to accounts in Dubai and Cyprus. Open-source analysis, in French and in English, reveals that the beneficial owner is the brother of a minister responsible for natural resources, a piece of information the client had not declared when the account was opened. The head of compliance documents the analysis in ten pages, consults the compliance committee, freezes the account and submits a report to the Money Laundering Reporting Office, which passes the case on to the Office of the Attorney General of Switzerland. The bank terminates the relationship, retains the documents for ten years and trains its advisers to detect family ties with politically exposed persons. The cost of the analysis is around CHF 20,000, whereas the cost of a FINMA sanction for a failure of due diligence would have been out of all proportion.

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.

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Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

My approach is to act as a trusted advisor who works directly with decision-makers, on an equal footing: I start from what you want to achieve and shape every structure, contract and tax decision around your commercial goals and how it improves your after-tax return. As “lawyers who make it happen”, my team and I stay involved until your company is set up, your structure is in place and your transaction has closed, and we remain available for any follow-on work that may be required. You benefit from bespoke solutions and personal attention, and sound, friendly and practical advice. We are not the lowest-cost provider in the market, nor do we intend to be; our aim is to deliver well-founded, proper solutions and excellent value for money.

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