Notice of an administrative fine by the Norwegian Financial Supervision Authority

02 Nov 2022 18:04 CET

In April 2021, Santander Consumer Bank AS (SCB or the “Bank”) informed the
Norwegian FSA (N-FSA) about certain self-detected weaknesses in the anti-money
laundering (AML) and counter terrorist financing (CTF) control environment.

In September 2021, the N-FSA conducted an inspection of SCB’s compliance with
the Information and Communication Technology (ICT) and AML/CTF-regulations. The
scope of the inspection was our Norwegian business. The report following the
inspection shows weaknesses in the Bank’s systems and routines. SCB has been
aware of and has worked to rectify these matters both before the inspection and
in the period after it was carried out.

It is important to emphasize that there is no suspicion of money laundering in
any specific case. AML/CTF has been, and continues to be, an area of the highest
priority for the Bank, although some measures have taken longer to implement
than initially expected. SCB has heavily invested in this area and improved in
the period of time following the last inspection.

Based on the report, the N-FSA has imposed an administrative fine on SCB of NOK
150.000.000. The fine is not the result of a suspicion of money laundering in
any specific case, but relates to deficiencies in the Bank’s routines and
systems for risk assessments, reporting and follow-up, and control of the
customer portfolio.

It is SCB’s utmost priority to rectify these matters. We are working
purposefully and are fully committed to close nonconformities discussed in the
report as soon as possible.

Since May 2021, the Bank has implemented a set of changes with the aim of
strengthening the compliance level with the AML/CTF regulations. The Bank has,
inter alia, improved the business risk assessment methodology, implemented a new
customer risk classification model, expanded the transaction monitoring and
invested in new AML/CTF system capabilities. In addition, the Bank has
strengthened the capacity in the AML/CTF function.

It is of great importance to SCB to maintain an open and good relationship with
the N-FSA. The Board sent the N-FSA a thorough response to the preliminary
report. Although we have different views on some assessments, we agree with the
overall conclusions. We are reviewing the report and will use its content to
further strengthen our efforts to combat money laundering and terrorist
financing.

SCB has decided to accept the fine in order to have a forward leaning focus, not
least on continuous improvements of the Bank’s AML/CTF-capabilities.

Contact:
Eskil Pedersen, Nordic Communication Director, +47 46852660
Eskil.pedersen@santanderconsumer.no

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