When Credit Suisse Services AG pleaded guilty in May 2025, the U.S. Department of Justice spotlighted at least 475 undeclared offshore accounts—still active years after the bank’s 2014 plea agreement—and secured over $510 million in fines. Financial institutions face growing pressure to close these gaps before investigators do. But manual reviews and siloed systems simply cannot scale to monitor thousands of customer profiles and their evolving risk signals. For institutions that hold themselves to high standards of regulatory compliance, evolving their Risk technology with tools like automated KYC & EDD is as important as prioritizing a high-quality culture of compliance.
Willful acts by Credit Suisse
According to the Justice Department, Credit Suisse AG, which had ultra-high-net-worth and high-net-worth individual clients around the globe, “conspired with employees, U.S. customers, and others to willfully aid U.S. customers in concealing their ownership and control of assets and funds held at the bank.”
Credit Suisse thereby enabled U.S. customers to evade U.S. tax obligations. Methods included opening and maintaining undeclared offshore accounts for U.S. taxpayers at Credit Suisse AG. Among other fraudulent acts, “bankers at Credit Suisse falsified records, processed fictitious donation paperwork, and serviced more than $1 billion in accounts without documentation of tax compliance.”
With these actions, Credit Suisse AG committed new crimes and breached its May 2014 plea agreement with the United States.
The glaring risk of undeclared accounts
Investigators found that Credit Suisse bankers conspired, from 2010 through mid‑2021, to conceal U.S. ownership by falsifying records and leaving key reports unfiled. Those omissions persisted through 475 accounts, many of which moved tens of millions across borders. In today’s climate of heightened enforcement, every missed refresh or misflagged account threatens not only hefty fines but also severe reputational damage.
RegTech solutions: Automated KYC & EDD refreshes
Leading RegTech and AML solutions like RegTechONE automate risk‑based KYC refresh cycles. Instead of relying on quarterly or annual manual checks, your RegTech solutions should trigger real‑time reviews whenever a customer’s risk profile shifts. For example, RegTechONE® platform functionality ingests and orchestrates data from myriad sources that can include the following:
- External watchlists (OFAC, UN, EU)
- Internal risk indicators (transaction velocity, geographic exposures)
- Unstructured inputs (document uploads, email attachments
- Any array of internal and external data sources
When the system detects any red flag, it can instantly rerun identity verification and risk scoring. Compliance teams receive an immediate alert, and the platform logs every action in a tamper‑proof audit trail.
Enhanced Due Diligence on steroids
Financial institutions often struggle to allocate scarce resources for Enhanced Due Diligence (EDD). Platforms like RegTechONE enforce dynamic, rule‑driven EDD workflows. You define your risk thresholds, and the system can automatically initiate the following actions:
1. Auto‑collects supporting documents (e.g., source‑of‑fund statements)
2. Assigns specialized review tasks to senior analysts
3. Escalates unresolved exceptions after predefined SLAs
This orchestration sharply reduces average Enhanced Due Diligence turnaround, liberating teams to focus on high‑priority investigations rather than paperwork.
Self‑trained AI/ML models: Powering proactive escalations
Every compliance decision you make—from approving a high‑risk corporate account to flagging an unusual wire transfer—becomes part of Directed Intelligence on RegTechONE. The platform uses that institutional history to train bespoke AI/ML models. Imagine training models to take on tasks like spotting patterns unique to your client base, predicting which profiles require next‑level scrutiny, and continuously learning from analyst feedback.
Rather than applying generic rules, these self‑trained models fine‑tune themselves to your workflows. When a model spots a novel risk fingerprint—say, a cascade of small deposits structured to evade reporting—it can flag it immediately for EDD, long before manual teams catch on.
Building a culture of proactive compliance
Regulators no longer accept “we missed that” as an excuse. Institutions must demonstrate robust, data‑driven controls that adapt in real time. With today’s RegTech solutions, institutions can choose to automate KYC refreshes, supercharge EDD workflows, and leveraging self‑trained AI/ML agents. With solutions like RegTechONE, institutions empower their compliance team to prevent the next “475” from slipping through.
Take the next step
Don’t wait for enforcement actions to expose hidden gaps. Schedule a demo of RegTechONE today and discover how automated KYC and EDD can turn your compliance operation from reactive to relentlessly proactive.
