Preventing and Detecting Unusual Transactions Across Santander Group to Protect Customers and the Financial System in All Markets

Within the financial system, the prevention, detection and reporting of unusual or suspicious transactions is an ongoing responsibility. Banks play a fundamental role in protecting their customers, safeguarding the integrity of the financial system and supporting the proper functioning of markets through controls, transaction monitoring, suspicious activity reporting, corporate governance mechanisms and cooperation with regulators and competent authorities.

At Banco Santander, this approach is implemented through controlled processes designed to identify, review and escalate potentially suspicious activities. The objective of these processes is to help protect customers, the financial system and the Bank itself from the potential misuse of financial products, while safeguarding confidentiality, data protection and customers’ rights.

Santander Group maintains a zero-tolerance policy towards financial crime and requires strict compliance with all applicable anti-money laundering (AML) and sanctions regulations. During 2025, the Group submitted more than 311,000 suspicious activity reports to the relevant authorities, reflecting the scale and intensity of its efforts to identify, analyse and escalate potentially irregular activities across the markets in which it operates.

An Ongoing Approach to Prevention and Control

Santander has control, monitoring and governance mechanisms designed to identify warning signs, analyse transactional behaviour and act in accordance with applicable regulations whenever a transaction warrants further review.

This framework incorporates multiple layers of oversight, including internal procedures, monitoring tools, due diligence processes, case escalation mechanisms and coordination among compliance, risk, operations and internal control teams. The management of unusual or potentially suspicious transactions does not rely on any single measure, but rather on a comprehensive set of processes that are continuously reviewed and strengthened. This approach enables the Bank to respond to potential risks, safeguard customer information and comply with the legal obligations governing financial institutions.

Cooperation with Competent Authorities

In accordance with applicable regulations and supervisory requirements, Santander carries out the due diligence processes required under both international and local regulations across the jurisdictions in which it operates and cooperates with competent authorities within the relevant legal framework.

Such cooperation is particularly important in ongoing investigations, where confidentiality and respect for institutional procedures are essential. For this reason, there are limits on the information that a financial institution may publicly disclose regarding potentially irregular transactions, individuals under investigation or matters that form part of judicial proceedings, in order not to compromise the effectiveness of criminal investigations.

Notwithstanding these limitations, Santander maintains a policy of active cooperation with regulators and authorities, providing relevant information when required and always acting in accordance with the law.

A Recent Example of the Bank’s Management of Unusual Transactions

A recent example is the investigation linked to Tren de Aragua in Chile, publicly known as Operation Tokyo. Santander Chile and the prosecutor in charge stated at the time that the investigation is focused on individuals who allegedly acted in a personal capacity and does not involve the Bank as an institution.

Based on the information available to date, the case concerns alleged individual conduct attributed to a former employee, who the bank immediately dismissed and filed a lawsuit against. Furthermore, given the functions he performed within the Bank, he did not have access to systems that would have enabled him to open current accounts or execute international money transfers. Santander Chile has also confirmed that customer information has not been compromised.

In this context, and while respecting the confidentiality requirements of an ongoing criminal investigation, the Bank carried out the appropriate actions before the competent authorities and adopted the necessary measures in accordance with applicable legislation. In addition, these developments were communicated to customers and employees, in line with the Bank’s commitment to providing clear, transparent and timely information to its stakeholders.

A Coordinated Effort

In conclusion, preventing suspicious transactions requires coordinated efforts among financial institutions, authorities, regulators and other competent bodies.

As demonstrated by the case in Chile, the Bank always acts in accordance with the law, actively cooperating with the authorities and continuously strengthening its internal processes in order to contribute to clarifying the facts and supporting the determination of any responsibilities that may arise.