Santander was aware that there were significant weaknesses in its AML systems and a programme of improvements ensued in 2013. While there were minor improvements, the bank realised that these actions did not adequately address the underlying weaknesses and, in 2017, a comprehensive restructuring started - a programme that Santander continues to invest in. Santander has not disputed the FCA's findings and has agreed to settle, which means it has qualified for a 30% discount. Without the discount, the financial penalty would have been £153,990,400. In the past, the FCA have fined Standard Chartered Bank £102.2 million for failing AML systems, HSBC Bank plc £63.9 million, NatWest £264.8 million. Mark Steward, executive director of enforcement and market oversight at the FCA, says: "Santander's poor management of their anti-money laundering systems and their inadequate attempts to address the problems created a prolonged and severe risk of money laundering and financial crime.