In particular, HSBC failed to: HSBC did not dispute the FCA's findings and agreed to settle at the earliest possible opportunity, which meant it qualified for a 30% discount. Otherwise, a financial penalty of £91.3m would have been imposed. HSBC has since undertaken a large-scale remediation programme into its anti-money laundering processes, which was supervised by the FCA. Mark Steward, executive director of enforcement and market oversight at the FCA, said: "HSBC's transaction monitoring systems were not effective for a prolonged period despite the issue being highlighted on numerous occasions.