ING Bank Money Laundering Settlement

As of October 2026: As of October 2026 the facts of the 2018 settlement are taken from the prosecutors' own press release. The 2024 decision not to prosecute Ralph Hamers and the December 2025 Court of Appeal ruling are reported through Dutch news outlets; the court's ruling text was not reviewed, and the exact ruling date is the date of the NOS report. Later regulatory or civil steps by DNB or investors were not reviewed.

Also known as: ING €775 million settlement · ING Netherlands money laundering case · ING Dutch AML settlement 2018.

What happened?

ING is the largest bank in the Netherlands. In early 2016 the Dutch fiscal investigation service (FIOD) began looking at the bank after finding that customers suspected in other criminal cases held accounts at ING Netherlands. The inquiry grew into a review of how the bank checked its customers and watched their accounts between 2010 and 2016.

On 4 September 2018 the Dutch Public Prosecution Service announced a settlement. ING Bank N.V. paid €775 million: a €675 million fine and €100 million in disgorgement of what the bank had saved on compliance staff. Prosecutors said the bank had broken the Dutch anti-money laundering law (Wwft) for many years and was culpable of money laundering, because accounts at ING Netherlands had been used to launder hundreds of millions of euros.

Which techniques did it use?

This is a case about a bank’s weaknesses, and the prosecutors’ statement of facts gave four anonymised examples of how accounts were used:

• A telecom provider moved bribes worth tens of millions of dollars through ING accounts to a company owned by the daughter of the then president of Uzbekistan. The bank’s report of the unusual transactions came far too late and the real owner had not been properly checked. That is the beneficial owner problem seen in shell company structures.
• A lingerie trader was alleged to have laundered about €150 million. Monitoring alerts were set aside as “not unusual” with almost no further inquiry.
• A one-person building materials business with no Dutch address had mobile ATMs linked to its account placed and used in Suriname, where they worked like a currency exchange. About €9 million passed through with very little due diligence.
• Two connected fruit and vegetable importers deposited more than €500,000 in cash in a year. Only one deposit was flagged, and the report to the financial intelligence unit was very late. This fits the pattern of cash-intensive businesses.

How was it found?

The route was investigative, not a whistleblower or a news story. FIOD began its work in early 2016 after finding suspects in other cases who banked with ING Netherlands. The prosecutors said other signals from other investigations and media reports pointed the same way but were not examined in detail. DNB, the Dutch central bank, had also warned ING Netherlands several times and taken formal measures, and prosecutors said the bank knew from 2010 that its policies were not being carried out properly.

What was the outcome?

• Corporate settlement. ING paid €775 million on 4 September 2018. Prosecutors cited the seriousness of the facts, ING’s cooperation and its remediation programme, which was under close DNB monitoring. They called it a systemic bank that “bears a great responsibility”.
• No individuals named. Prosecutors said the offences could not be attributed to individuals, including senior managers, and the investigation did not show that anyone consciously steered or failed to stop them.
• Former CEO. After pressure from an activist, prosecutors investigated the personal role of Ralph Hamers. In December 2024 they said there was insufficient lawful and convincing evidence, while noting that he knew of weaknesses, that an internal audit report and an alarming email from the head of legal affairs had raised concerns, and that a 2015 board analysis concluded everything was in order. On 3 December 2025 the Hague Court of Appeal ruled that he would definitively not be prosecuted, saying the offences were nearly time-barred and the case had already confirmed that bank executives are not off the hook if they do not take responsibility.

What were the warning signs?

• Missing or thin customer checks. Prosecutors found due diligence was insufficient or absent, and some customers were placed in the wrong risk segment.
• A monitoring system that raised few alerts. Only “the proverbial tip of the iceberg” was investigated.
• Reports filed late or never. Unusual transactions were often not passed to the financial intelligence unit, or were passed too late.
• Relationships that should have ended. The bank was slow to end relationships with customers who showed signs of risk.
• A small and under-trained compliance team whose responsibilities were spread across three divisions, with no one overseeing the whole picture.
• Cash and unusual structures that did not fit the stated business. Cash deposits into importers’ accounts and a firm with no local address were both flagged by prosecutors after the fact.

What changed afterwards?

ING ran a remediation programme under DNB supervision, and the prosecutors treated it as a reason for restraint in the size of the settlement. The case also fixed an expectation that a Dutch bank is a gatekeeper that must know who its customers are, watch what they do and report what looks odd, whether the customer is a multinational or a small firm.

The settlement was followed by the ABN AMRO settlement in 2021 and a criminal case against Rabobank that was still in the courts in 2026, so Dutch prosecutors have now looked at all three big domestic banks. See transaction monitoring and know your customer for what banks are expected to do.

First published October 21, 2026 · Last updated October 21, 2026 · Legal statuses current as of October 2026