Margaret Cole, FSA director of enforcement and financial crime, says: "Firms must ensure their systems and controls develop at the same rate their business operations grow; if this doesn't happen - as in Nomura's case - they run the risk of having systems that are inadequate for their business." She says Nomura breached two FSA Principles as the firm failed to conduct its business with due skill, care and diligence and failed to take reasonable care to organise and control its affairs responsibly. "Financial instruments must be valued correctly by traders and a firm's systems and controls must be able to minimise the risk of traders mis-marking their positions," says Cole. "When a firm's systems and controls fall short of required standards, we will not hesitate to take action." Nomura qualified for a discount on the fine for agreeing to settle with the FSA at an early stage in the investigation. Without the discount, the financial penalty would have been £2.5 million.