Credit Suisse thought it had ‘come clean’ in 2014 when it pleaded guilty to helping Americans evade their taxes and promised to help the U.S. root out suspicious accounts. Now in 2016, U.S. investigators - federal prosecutors, the SEC and the IRS - are asking why the bank neglected to tell them about $200 million in undeclared assets owned by client Dan Horsky, who’s a citizen of the U.S., the U.K. and Israel.

Was the failure to disclose simply a lapse in internal controls? Was it a crime involving bankers who acted with approval of managers? Are there any other undisclosed accounts? In any case, based on results of the investigation, Credit Suisse could face a new civil or criminal case.

Horsky pleaded guilty 11/4/16 to conspiring to defraud the IRS, and has been cooperating for more than a year with investigators examining whether the bank helped clients with ties to Israel evade U.S. taxes.