We have already had a successful outcome in this case, fining Julius Baer over £18m. The firm allowed improper commission payments of around $3m (USD) to be made to a finder and its failures created circumstances where financial crime could flourish.

There were obvious signs that the arrangements between Julius Baer and the finder were potentially improper and corrupt. These were serious failings so it was clearly in the public interest for us to examine the conduct of the individuals who were most closely involved.

The Upper Tribunal was critical of many aspects of the conduct of each of the individuals in this case, albeit it has found that such conduct was negligent rather than reckless. As we made clear when we first publicised this case, this was an important case to bring because it concerned serious risks of financial crime. The Tribunal agreed with many of our arguments including that suspicious transactions should have been stopped.

This was a complex multi-party investigation involving thousands of documents. One document of limited significance was not disclosed that should have been as a result of human error. While human error cannot ever be eliminated completely, we take seriously the Tribunal’s recommendations and are reviewing our disclosure processes.

While we recognise some of the characterisation surrounding delays in this case many of them were outside of our control.