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Alexandra Wrage
President and Founder, TRACE


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Nicola Bonucci 
International Lawyer and former
Director for Legal Affairs OECD
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Dave Lee
FCPA Compliance Consultant, TRACE
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Sunny McCall
Senior Director II, Compliance Training, TRACE
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Lee Nelson
Independent Compliance and
Ethics Attorney
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Jessica Tillipman
Associate Dean for Government Procurement Law, The GW University Law School
  • Writer's pictureDave Lee

A Four-Part Series: Part 1- Hook, Line, and Sinker: The Mozambique tuna bonds scandal

Mozambique beach side boats

Many readers will already be familiar with the so-called tuna bonds scandal, where Credit Suisse and affiliates of VTB, the state-owned Russian Bank, provided or arranged loans to three entities that were created with the claimed purpose of developing a lucrative tuna fishing industry in Mozambique. Those companies were known as ProIndicus (which would provide security for the coastal and fishing waters), Ematum (which would operate the fishing endeavor), and MAM (which would service the boats).

Together, they would borrow more than $2 billion in 2013 and 2014 – a sum that amounted to roughly 12% of the country’s GDP.

The loans had been secured with government guarantees that the state’s finance minister made (and hid) without the right approvals, and much of the proceeds were diverted for other purposes – including to pay more than $200 million in bribes. The commercial venture imploded within its first few years, and Mozambique sank into a fiscal spiral once further details of the loans became public.

U.S., UK and Swiss regulators would later charge Credit Suisse under laws relating to fraud and money-laundering, as well as the books and records and internal control provisions of the FCPA. Those charges were settled in 2021, with the bank agreeing to pay nearly $475 million in penalties, and to forgive $200 million of debt owed by Mozambique.

Following the enforcement actions, Mozambique was still left with billions in debt to banks and other creditors. Not surprisingly, a web of commercial litigation ensued.

The staggering amount of the loan should have been a clear warning that the project was commercially unrealistic, which in turn should have been viewed as a red flag for corruption risk. This series will examine other signs of commercial risk – much of which is not discussed in the enforcement papers – with an eye towards helping practitioners and stakeholders develop a more robust and holistic view of risk assessment and management.

FCPA Compliance Consultant, TRACE



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