Kara para aklama ve terörizmin finansmanına karşı mücadele kanunlarına aykırılık sebebiyle Hollanda savcılığınca ING Bank (Hollanda)’ya verilen 775 milyon EUR’luk para cezasının sebepleri aşağıdaki yazıda bulunabilir. ING Bank tarafından yapılan hatalı uygulamalar ve cezanın mesnedine ilişkin detaylı bilgi izleyen sitede yer almaktadır.

4 September 2018, ING Bank N.V. (ING) in Amsterdam has accepted and paid a settlement of EUR 775,000,000 offered by the Netherlands Public Prosecution Service (NPPS). The NPPS has accused ING in the Netherlands of having violated the Anti-Money Laundering and Counter Terrorism Financing Act (AML/CTF Act) for many years and on a structural basis. This took place in such a way that the bank is also accused of culpable money laundering: the bank failed to prevent bank accounts held by ING clients in the Netherlands between 2010 and 2016 from being used to launder hundreds of millions of euros.

The investigation by the Dutch Authorities started at the beginning of 2016. The reason was that companies or individuals that had come under suspicion in several criminal investigations held accounts with ING NL, leading to suspicions that ING NL was not sufficiently investigating clients, was insufficiently monitoring bank accounts and did not report unusual transactions, or reported them too late.

Over the course of this investigation, the suspicion arose that ING NL's behaviour with regard to these specific clients was not just an isolated incident, but the result of structural shortcomings at ING NL in implementing the policy to prevent financial economic crime. The absence or insufficient conducting of client due diligence led to ING NL’s acceptance of clients without sufficiently investigating the risks associated with those clients. Clients were also classified in the wrong client segments. Client relationships and bank accounts were not sufficiently monitored and, when necessary, not terminated by the bank in a timely manner. The compliance department was understaffed and inadequately trained. Partly due to the limited personnel capacity, the system for monitoring transactions was set up by the bank in such a way that only a limited number of money laundering signals were generated. Only the proverbial tip of the iceberg was investigated. In short, the bank did not sufficiently recognise the risks of money laundering. If an unusual transaction was nevertheless recognised, it was regularly not reported to the FIU, or was reported too late.


1-An international telecom provider transferred bribes worth tens of millions of dollars via its bank accounts with ING NL to a company which was owned by the daughter of the then president of Uzbekistan. ING NL reported the unusual transactions to the FIU far too late. In addition, ING NL did not sufficiently investigate the identity of the actual owner of the company.

2-According to the NPPS, a women's underwear trader was also able to launder approximately EUR 150,000,000 through its bank accounts held with ING NL. It should have been clear to the bank that the monetary flows had little to do with the lingerie trade and were therefore unusual. The NPPS has accused the suspects in this case of laundering hundreds of millions of euros of criminal money. Here, too, the bank did not conduct sufficient client due diligence and the company was classified in the wrong segment. The monitoring system did generate alerts regarding unusual monetary flows, but these were wrongfully and almost without further investigation set aside by the bank as 'not unusual'.

3-Another case concerns a one-man business in building materials with no address in the Netherlands. The company had a business account with ING NL to which 15 mobile ATMs were linked. Contrary to ING’s rules, these mobile ATMs were placed and used by the one-man business in Suriname. They were allegedly to be used for purchases. Investigations have shown that the one-man business actually acted as a currency exchange office. A total amount of EUR 9,000,000 was transferred to the one-man business’ bank accounts with ING NL, even though no building materials were purchased for that amount.  In reality, debit cards were used in the mobile ATMs in Suriname in exchange for cash. ING NL carried out almost no client due diligence and the company's transactions were not properly monitored.

4-A case was also investigated in which, over a year, more than EUR 500,000 was deposited in cash into the ING bank accounts of two connected companies. These companies were apparently involved in the import of and trade in fruit and vegetables from South America. This was probably a front for money laundering. Only one of the cash deposits was flagged by the bank as potential money laundering. In addition, ING NL was far too late in reporting an unusual transaction to the FIU.

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