Credit Suisse shareholders have taken RICO claims to the Southern District of New York, seeking damages for what they say are billions in losses attributable to the bank’s conspiracy with former auditor KPMG.

A class action complaint was filed Wednesday by Bottini & Bottini, the Law Office of Alfred G. Yates Jr. and Nevada attorney Byron S. Georgiou, claiming two RICO violations and breaches of duties to shareholders under both Swiss and New York law.