The UK's thematic review of how banks in the UK manage money-laundering risk in highly risky situations, which the old Financial Services Authority launched in June 2011, is still disgorging its load of disciplinary cases. The latest is that of a relatively new London bank with a large Nigerian parent, Guaranty Trust Bank (UK) Ltd, which has to pay £525,000 ($812,522) by 22 August.

In its final notice to the bank, published last week, the Financial Conduct Authority, the FSA's successor, does not make it plain whether the bank caters mainly to high-net-worth individuals, referring in its preamble to “retail business”. The only actual sum mentioned regarding someone's account, however, is $500,000, which suggests that high net worth individuals formed a healthy part of the bank's clientele. Moreover, 18 of the 51 customer files in the old FSA's survey were those of PEPs, who rarely fail to qualify as high net worth individuals.

As in previous cases, the bank has paid a heavy price for the investigation. It has spent large undisclosed sums beefing up its anti-money-laundering systems and controls. It has invested heavily in more IT, taken on more compliance people and hired a compliance consultant, also unnamed, to help it manage financial crime risk. As always, the fine is merely the coup de grace which comes on top of a massive waste of management time and attention.