Grupetta said he was astounded that his team could still visit banks and review files that had cleared their processes but which nonetheless indicated major risk and showed that the same highly questionable judgments were being made.

The upshot of this investigation is likely to be another review with another concomitant string of penalties. The 2011 review – which the FSA trumpeted as a new type of more intrusive investigation to be followed in future - resulted in a “duck shoot”.

In April, the newly-minted FCA fined EFG Private Bank Ltd £4.2 million ($6.36 million) for inadequate controls that the review had detected.

Other fines that sprang from the last thematic review were imposed on Coutts (£8.8 million) and Turkish Bank UK (£294,000).