Leah Moushey commented on Credit Suisse's recent settlement with the U.S. Department of Justice (DOJ), the Securities and Exchange Commission (SEC), the United Kingdom's Financial Conduct Authority (FCA), and the Swiss Financial Market Supervisory Authority (FINMA) in a $547 million coordinated global settlement that includes $200 million of loan forgiveness. The SEC settlement involved alleged violations of the books-and-records and internal controls provisions of the Foreign Corrupt Practice Act (FCPA), while in the DOJ settlement, the bank only pled guilty to conspiracy to commit wire fraud. Moushey told Anti-Corruption Report that the case highlights the need for financial institutions to take a holistic approach to reviewing deals. "The message for financial institutions from these events is that risk mitigation systems must drive visibility into transactions as they evolve and that bank internal controls must be sufficient to stop risky transactions in the face of red flags if appropriate," Moushey said, adding that "[p]art of this is making sure decisions are not made in silos, and ensuring that the right people have eyes on the issues."