As we’ve seen over the last eight years, global mega-banks rarely launch internal investigations on their own volition. Instead they come one step ahead of a legal inquiry into their criminal activities, whether that’s market manipulation, money laundering, violating sanctions, preying on vulnerable customers or perjury.

So when Swiss bank Julius Baer said on Wednesday it has opened an internal investigation in connection with the FIFA corruption scandal, this likely means the bank is squarely in the crosshairs of U.S. regulators investigating bribery, corruption and money laundering within soccer’s governing body.

Julius Baer, Switzerland’s third largest public bank, was one of a number of banks mentioned in the U.S. Department of Justice’s May charge sheet against FIFA officials.

“We have launched an internal investigation,” a spokesman for Julius Baer said. “We are fully cooperating with the authorities.”

The spokesman declined to say when the investigation began, or with which authorities it was cooperating with, but it is likely doing what banks normally do to avoid criminal prosecution – cooperate, say sorry, pay a fine and move along.

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