Allegations
(i) Credit Suisse had deficient disclosure controls and procedures and internal control over financial reporting; (ii) Credit Suisse’s practice of lending money to Russian oligarchs subject to U.S. and international sanctions created a significant risk of violating rules pertaining to those sanctions and future sanctions; (iii) the foregoing conduct subjected the Company to an increased risk of heightened regulatory scrutiny and/or enforcement actions; (iv) the Securitization Deal, in which Credit Suisse sold off $80 million worth of risk related to a $2 billion portfolio of loans backed by assets owned by certain of the bank’s ultra-high net worth clients, concerned loans that Credit Suisse made to Russian oligarchs previously sanctioned by the U.S.; (v) the purpose of the Securitization Deal was to offload the risks associated with these loans and mitigate the impact on Credit Suisse of sanctions likely to be implemented by Western nations in response to Russia’s invasion of Ukraine; (vi) Credit Suisse’s request that non-participating investors destroy documents related to the Securitization Deal was intended to conceal the Company’s noncompliance with U.S. and international sanctions in its lending practices; (vii) the foregoing, once revealed, was likely to subject the Company to enhanced regulatory scrutiny and significant reputational harm; and (viii) as a result, the Company’s public statements were materially false and misleading at all relevant times.