Leaked Letters Give Insight Into Anti-Money Laundering Gaps at Swiss Bank Reyl

Swiss private bank Reyl Intesa Sanpaolo takes pride in its global reach and "responsible culture." Headquartered in a stately building in one of Geneva’s most exclusive neighborhoods, it describes itself as a customer-focused organization offering "solutions addressing the increasingly complex needs of its clients."

But behind closed doors, the bank has come under scrutiny from regulators over this client roster, which includes the children of Central Asian autocrats and other figures who present a risk of money laundering.

Correspondence between the bank and the Swiss Financial Market Supervisory Authority (FINMA), obtained by OCCRP and Le Monde, shows that Switzerland’s financial regulator has investigated Reyl for “weaknesses in the area of money laundering” and alleged failures in its handling of high-risk accounts.

Several detailed letters from FINMA to Reyl, along with responses from the bank, reveal how an on-site FINMA inspection in the summer of 2023 found “a very high level of AML [money laundering] risk appetite, as well as a certain carelessness in the way you discharged your due diligence duties.”

According to a letter it sent the bank in January 2024, FINMA escalated its inquiries to its enforcement division, which investigates breaches of regulatory law.

While FINMA cannot bring charges, it can file complaints with Swiss criminal authorities — and is obligated to notify them if it detects corporate or business fraud. It can also revoke a bank license, confiscate illegally earned profits, and issue an industry ban against individual bankers. 

There is no evidence that FINMA has filed a complaint or taken other enforcement action against Reyl. It told journalists it could not comment on specific cases. 

Reyl also declined to comment on any specific cases, but said it was “cooperating fully with the supervisory authorities and places the highest priority on ensuring compliance with all applicable regulations and continuously strives to enhance its internal processes and controls.”

The bank also said that it had filed a complaint with Swiss authorities over the questions sent by OCCRP and its reporting partners: “The information you have submitted is confidential, subject to banking secrecy obligations under Swiss law. The Bank, considering itself a damaged party due to the breach of banking secrecy, has therefore filed a complaint against unknown persons with the Swiss authorities in order to safeguard both the institution and its clients.”

Switzerland’s highly secretive banking sector is protected by draconian laws that prioritize the privacy of bank customers, and restrict journalists from reporting on them.

Authorities have insisted that the country has robust anti-money laundering regulations that can adequately police the banking sector even as it maintains its traditional secrecy. But the new findings show that Switzerland’s banks remain a destination of choice for international clientele, some with murky sources of wealth. 

In its correspondence with the bank, FINMA raised questions over Reyl’s handling of accounts belonging to six high-risk clients, including a former Russian minister, the son-in-law of the late Uzbek strongman Islam Karimov, and a Swiss asset manager who managed companies for the children of Azerbaijani dictator Ilham Aliyev. (None of these clients responded to requests for comment.)

The regulator also asked the bank about the daughter of Kazakhstan’s former president, who is now under criminal investigation in Switzerland over the source of the tens of millions of francs she holds at Reyl. (Her lawyer told OCCRP she has always cooperated with authorities in declaring the source of her wealth)

The Clients Who Raised Questions

A September 2023 letter from FINMA presented the findings of an on-site inspection at the bank’s Geneva headquarters the previous month, and described its anti-money laundering measures as “unsatisfactory.” The letter warned that Reyl remained in the regulator’s "very high" risk category in terms of potential for money laundering.

Inspectors found that thousands of high-risk transaction alerts — internal warnings triggered automatically by suspicious money movements — had been left unchecked by bank staff for two or more months. They also discovered that more than 1,400 accounts had not been subject to a “know your customer” review for more than five years. 

There were also “risks of conflicts of interest” over the role of François Reyl, the bank’s managing director at the time, who inspectors said had directly managed customer relationships worth more than 1.2 billion francs ($1.4 billion), on a key bank committee that voted on whether to accept new customers. François Reyl stepped down as Reyl's managing director in July 2024 but is still a board member and senior partner.

Justyna Gudzowska, executive director of The Sentry, a Washington, D.C.-based NGO that investigates kleptocracy, told OCCRP that a bank should ensure it has robust controls if it takes on risky clients. 

“If you're going to have a high risk appetite, you better make sure that your anti-money laundering framework is in tip-top shape,” said Gudzowska, who formerly worked as an in-house lawyer for the U.S. investment bank Morgan Stanley.

In its September 2023 letter, FINMA tasked Reyl with implementing a series of recommendations over the following months, and asked the bank to “sharply reduce or even halt” taking on new high-risk or politically exposed customers in the meantime.

On January 31, 2024, FINMA informed the bank that its file had been “transmitted to the Enforcement Division to carry out additional investigations.” The letter noted specific concerns over Reyl’s “business relations linked to Russia.”

Despite the apparent escalation of the case, “no enforcement proceedings” had yet been opened against the bank, FINMA wrote in the January 2024 letter.

A System That Safeguards Secrecy 

Exposés of Swiss banks Credit Suisse, HSBC Suisse, and UBS have revealed evidence of industrial-scale money laundering and tax evasion over the years, but such glimpses of high-risk banking activity in Switzerland remain rare due to the extreme secrecy shrouding the sector. 

A law dating back to the 1930s means bank employees can be jailed in Switzerland for sharing customer information with third parties, even if they want to expose wrongdoing. Since 2015 the law has also applied to journalists, activists, and others.

Transparency advocates say the law silences whistleblowers and journalists working in the public interest. “The Swiss Banking Act is an example of the criminalization of journalism,” Irene Khan, the U.N.’s special rapporteur on freedom of expression, told OCCRP’s media partner Paper Trail Media. 

The Suisse Secrets investigation, coordinated by Süddeutsche Zeitung and OCCRP, revealed in 2022 that dozens of individuals involved in torture, drug trafficking, money laundering and corruption had banked with Credit Suisse.

But just over two months later, Swiss lawmakers voted against a proposal to loosen provisions in the Banking Act that criminalize reporting on sensitive bank data. In December 2023, Switzerland’s upper house of parliament passed a motion asking the country’s government to examine whether publication of any illegally obtained data — which could include information provided by a whistleblower — should be made a criminal offense.

It was in this highly protected environment that Reyl thrived. 

Founded in Geneva more than half a century ago by banker Dominique Reyl, it started out as a wealth management business before obtaining a banking license in 2010, shortly after the financier’s son, François Reyl, took over as managing director. 

In 2013, French media reported that the bank had helped a former French government minister hide undeclared funds in Switzerland. The bank later acknowledged facilitating the transfer of assets to offshore entities, including accounts in Singapore, for at least eight clients in 2009. François Reyl, whom a court judgement described as “the essential order-giver for the commission of the money laundering acts,” was convicted of money laundering in France in 2016 for his role in hiding the assets, and given a one-year suspended prison sentence, while the bank was fined around 1.9 million euros ($2 million). (François Reyl did not respond to a request for comment.)

That didn’t stop François Reyl from continuing to head the Swiss lender, and in May 2021 the bank merged with the Swiss branch of Italian banking giant Intesa Sanpaolo. The same year, Reyl was voted Europe’s “best private banking boutique” at the Global Private Banking Awards. In a 2021 Wolfsberg Group questionnaire—a tool designed to assess financial institutions’ anti-money-laundering frameworks — the bank declared that it was “fully committed to the fight against financial crime.”

But just six months later, in March 2022, FINMA carried out what it called “a first supervisory review” relating to Reyl’s anti-money laundering measures, and found “material weaknesses” in the bank’s systems.

It was to be the start of a series of questions from FINMA as it looked into how Reyl onboarded and handled high-risk clients.

Questions Mount Over Reyl’s Clientele

By the time FINMA had sent a write-up of its findings to Reyl at the end of September 2023, more red flags had publicly emerged. 

A group of investigative journalists, including OCCRP, had revealed in mid-September that Swiss asset management firm Finaport, which referred customers to Reyl, provided services to several high-risk Russian clients.

The spotlight suddenly fell on Reyl’s own clientele.

Those clients included Leonid Reiman, a telecommunications minister under Vladimir Putin during the 2000s and later a presidential adviser, and Russian nationals Liubov Komissarenko and Natalia Ponomarenko, who became clients of Reyl in 2022 despite red flags over the source of their wealth. 

In a 2006 decision covered by international media, a Swiss tribunal found that Reiman had forced a communications company to buy a firm he owned “for an exorbitant amount” in order to obtain operating licenses. The tribunal judgment, which was later upheld by the country’s Supreme Court, said Reiman’s "direct intent" was "to misappropriate for his personal enrichment assets majority-owned by the Russian Federation." 

Reiman was also investigated in Germany in connection with the alleged sale of telecommunications assets that he had improperly transferred to himself, but the case was dropped in 2012 when prosecutors said they were unable to secure evidence from uncooperative officials in Russia. 

A few months after the German investigation was dropped, Reyl began assessing Reiman as a prospective client, correspondence between Reyl and FINMA shows. François Reyl personally met with Reiman early in 2015, and the ex-minister became a customer. 

By September 2023, five Reyl accounts the bank described as “connected to” Reiman held assets worth 81 million francs ($94 million), the correspondence shows.

But just 11 days after OCCRP’s report into Finaport and its clients was published, naming Reiman, Reyl’s client acceptance committee decided to terminate Reiman’s accounts, citing reputational risk, the correspondence shows. (Five months earlier, the same committee had voted to continue the relationship on the basis that “no further negative news nor any unusual transactions were identified.”)

Reiman did not respond to requests for comment.

Reyl seems to have acted similarly with regard to Komissarenko and Ponomarenko, only moving to terminate their accounts when their names appeared as part of the Finaport investigation.

Komissarenko was the longtime romantic partner of Alexander Ponomarenko, who heads Mosvodokanal, a publicly owned Russian water supply and sanitation company. Natalia Ponomarenko is his daughter from another relationship. In its Finaport investigation, OCCRP reported that Mosvodokanal had awarded Komissarenko’s company millions of euros worth of contracts after Alexander Ponomarenko began heading the company in 2012.

 After Finaport referred Komissarenko to Reyl in 2022, emails show how a Reyl employee conducting due diligence raised concerns with Finaport over a public report that claimed Alexander Ponomarenko “helps [Komissarenko] in obtaining the necessary state contracts.”

Reyl’s anti-money laundering team initially declined to greenlight a relationship with Komissarenko in November 2022, citing reputational risks “related to the origin of the assets of the customer,” the correspondence shows. But the bank later approved the account opening after Komissarenko’s personal banker at Reyl provided additional information.

The March 2024 letter from Reyl to FINMA reveals how, on the very day reporters published their investigation into Finaport in September 2023, Reyl’s client acceptance committee recommended terminating relations with Komissarenko and Natalia Ponomarenko “due to the bad news.”

Neither Komissarenko nor Ponomarenko responded to a request for comment.

FINMA had referred to the Finaport investigation in the letter it sent the bank in September 2023. By January 2024, it was also requesting information about the family members and associates of notorious dictators in Azerbaijan and Uzbekistan. In May it added the daughter of Kazakhstan’s former leader — now subject of a criminal investigation in Switzerland relating to the source of the tens of millions she held at Reyl — to its list.

Reyl Quizzed Over Links To Azerbaijan’s Ruling Family

As part of its anti-money laundering investigations, FINMA homed in on a Swiss asset manager called Olivier Mestelan, a customer at Reyl who had longstanding financial ties to the family of Azerbaijan’s authoritarian president Ilham Aliyev.

Aliyev has been in power since succeeding his father, Heydar Aliyev, in 2003 and has continued a brutal crackdown on dissent while his family has become stupendously wealthy.

Khadija Ismayilova, an Azerbaijani investigative journalist, was jailed in 2015 on what many observers regarded as politically motivated corruption charges. Ismayilova had written a series of stories with OCCRP and Radio Free Europe/Radio Liberty in 2011 and 2012 revealing how Aliyev’s daughters directed several offshore companies that held stakes in a lucrative gold mine and a major telecommunications company in Azerbaijan.

The reporting named Mestelan as a co-director in those offshore companies. A classified U.S. government cable sent from Washington, D.C., to Baku in 2010, later published by whistleblower group Wikileaks, described Mestelan as a “top Azerbaijani official.”

In January 2024, FINMA instructed Reyl to disclose any ties it had with Mestelan, as well as any relationships “with a link to Azerbaijan.” 

Reyl told FINMA it had a business relationship with Mestelan’s Swiss asset management firm, Privaxis Services S.A., which Reyl classified as high-risk “because of his links with the ruling family in Azerbaijan.”

Reyl also told FINMA that it acted as custodian to two investment funds managing assets worth 413 million Swiss francs ($483 million) as of December 2023. One of the funds’ institutional subscribers, Reyl said, was Banca Privada d’Andorra, a private Andorran bank that has been in liquidation since U.S. prosecutors declared it a “financial institution of primary money laundering concern” in 2015. 

According to the correspondence, the Andorran bank acted as a nominee subscriber for the funds’ underlying investors, whom Reyl described as “Azerbaijani persons, some of which were connected to the ruling family in Azerbaijan. Mr. Mestelan personally was also listed as an underlying subscriber.” (Reyl did not name the funds or identify their other underlying investors in the correspondence).

But although FINMA had asked Reyl to disclose all of its links to Mestelan, Reyl did not mention in the correspondence obtained by OCCRP that its asset management subsidiary had co-founded a Maltese investment company with Mestelan in 2010.  

That investment company, initially called Privaxis Umbrella Fund Sicav Plc (later renamed Aladdin Umbrella Fund), had a sub-fund that held $30 million in deposits at the state-owned International Bank of Azerbaijan as of 2011, according to its annual report.

One of the Maltese company’s directors, Philippe Houman, was convicted of money laundering in France alongside François Reyl in 2016. The company was liquidated later that year. Neither Mestelan nor Houman responded to requests for comment.

How Suspect Central Asian Wealth Found A Home At Reyl 

Reyl also counted among its clients the son-in-law of a Central Asian strongman, and the daughter of another. 

Lola Karimova, the daughter of the late Uzbek autocrat Islam Karimov, and her husband, Timur Tillyaev, enjoyed a jet-setting lifestyle while Karimov was in power. By 2013 they had settled in Geneva, she told the BBC in an interview. 

In 2012, FINMA warned Swiss wealth management firm Fidurhône — where Tillyaev and Karimova were clients — that the relationship presented “particularly increased” risks, and two years later, asked Fidurhône to cut ties with them after finding that their companies’ account balances had soared to 190 million francs, according to a decision later published by Switzerland’s Federal Department of Finance.

When Fidurhône refused to cut ties, FINMA threatened to remove the company’s license. The Federal Department of Finance later fined Fidurhône’s founding partner for failing to report suspicious account activity relating to Tillyaev.

In 2020, Tillyaev’s company Liobel Limited Inc. became a customer of Reyl, correspondence obtained by OCCRP reveals. Tillyaev opened his own account with the bank three years later. As of December 2023, one of the accounts held 83 million francs ($97 million).

In January 2024, regulators ordered Reyl to hand over records relating to Tillyaev’s accounts, as well as information about all customers “with a link to Uzbekistan.” The bank told FINMA it was reassessing Tillyaev’s accounts “due to potential high reputational risks” following the publication of negative news about Lola’s sister, Gulnara Karimova.

Tillyaev did not respond to a request for comment.

The daughter of Kazakhstan’s longtime ruler followed a similar path. 

Nursultan Nazarbayev ruled Central Asia’s largest nation with an iron grip for the two decades following the collapse of the Soviet Union, consolidating power in his hands and suppressing freedom of speech and political opposition, even as a circle of businessmen close to him were able to amass enormous fortunes and influence. OCCRP previously found that he set up private charitable foundations that controlled assets worth almost $8 billion.

His daughter, Dinara Kulibayeva, settled in Switzerland in 2007, where she entrusted part of her fortune to Reyl, the leaked correspondence reveals. François Reyl personally managed the relationship for several years. 

But last year, Swiss regulators said they wanted to know where the tens of millions of francs deposited in Kulibayeva’s account came from. In May 2024, FINMA ordered Reyl to hand over its “complete client files” on the account and one other account held by Kulibayeva’s Luxembourg-based company, Regulus Holdings S.A., to which Reyl granted a 25-million-euro loan facility to buy real estate in France.

FINMA’s query followed the opening of criminal proceedings against Kulibayeva last April, after Reyl filed what’s called a “suspicious activity report” with Switzerland’s money laundering reporting office relating to activity on her accounts, correspondence between FINMA and the bank shows.

A lawyer for Kulibayeva told OCCRP that she had always cooperated fully with local authorities to provide information on the source of the funds she used to acquire her Swiss real estate.

“It is a matter of public record that our client's wealth originates from her shareholding in Halyk Bank, a Kazakh regulated financial institution, listed on the London Stock Exchange,” wrote the lawyer, Jean-Christophe Hocke. “This is also the case for the funds deposited with Reyl.”

In correspondence obtained by OCCRP, Reyl also told FINMA that Kulibayeva’s account was funded by dividend payments from Halyk Bank.

The leaked correspondence reveals that although Kulibayeva’s accounts were frozen in April last year, prosecutors gave Reyl permission to process around 650,000 francs ($760,500) through Kulibayeva’s account in May to cover her “personal expenses.”