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financeFinancial Services · 2018
ING Bank N.V.
ING Bank N.V. entered into a €775 million deferred prosecution agreement (schikking) with the Dutch Public Prosecution Service for systemic AML failures spanning multiple years, including critically deficient customer due diligence processes that enabled large-scale money laundering linked to criminal organisations, corruption, and sanctions evasion. The settlement comprised €298 million in disgorgement and €477 million in fines, making it the largest corporate crime settlement in Dutch history at the time. Senior management were separately investigated for individual criminal liability.
Fine Imposed€775M
Authority
Regulation
Wet ter voorkoming van witwassen en financieren van terrorisme (Dutch AML)
Max fineUp to €5M or 10% of annual turnover per violation
Statusactive
Key Takeaways
- Systemic AML compliance failures — particularly inadequate CDD and transaction monitoring — can result in criminal liability for major banks and nine-figure penalties reflecting the scale of illicit flows enabled by inadequate controls.