In a Final Notice issued on 28 March 2013 (but published on 24 April 2013), the FCA imposed a fine of £4.2 million (Stage 1: 30% discount) on the UK private banking subsidiary of the Swiss private banking group, EFGI Group, for failing to take reasonable care to establish and maintain effective controls against money laundering for its higher risk customers; to gather sufficient levels of enhanced due diligence material; and, to conduct adequate ongoing monitoring of higher risk customers. The behaviour breached Principle 3 and SYSC. The investigation had been triggered by EFG’s visit by the FSA as part of its 2011AML thematic review. EFG is the third bank to be fined in the UK in the last 18 months over anti-money laundering controls. Coutts and Habib Bank AG Zurich were fined £8.75 million and £500,000 respectively in 2012.