On 9 December 2003 the FSA fined Abbey National Asset Managers Limited (ANAM) £320,000 for failures in senior management arrangements, systems and controls between December 2001 and June 2003. The regulator found ANAM did not have appropriate systems and controls, was slow to address divisional compliance concerns arising from its Risk Mitigation Programme and from two dealing desks, and had insufficient compliance resource and management information. The breaches were of FSA Principle 2 (which requires firms to act with due skill, care and diligence) and SYSC rules on senior management arrangements; ANAM paid about £300,000 in compensation to clients, implemented detailed systems and controls in June 2003, and the FSA said ANAM’s early agreement of facts and settlement were taken into account when deciding the penalty.