The Hague Court of Appeal on 3 December 2025 approved the Dutch prosecution’s request to discontinue criminal proceedings against former ING CEO Ralph Hamers in the “Houston” money-laundering case, stemming from ING’s €775 million settlement in 2018 for systemic AML failures. This decision follows years of investigation, with prosecutors citing insufficient evidence for criminal liability despite acknowledging inadequate actions by Hamers and other executives.
The Hague Court of Appeal has granted the Dutch prosecutor’s request to stop criminal prosecution of Ralph Hamers, former CEO of ING, in connection with the bank’s major anti-money laundering (AML) scandal known as the “Houston” case. As reported by EFRI in their analysis on 2 December 2025, the court decision (ECLI:NL:GHDHA:2025:2436) confirms no senior executive will face a full criminal trial despite the €775 million settlement.
NL Times coverage on 3 December 2025 stated that Ralph Hamers will not be prosecuted further in the money laundering case, following the court’s approval of the prosecution service’s request to discontinue proceedings. This comes after ING paid a record €775 million fine plus disgorgement in 2018 for long-lasting, structural AML violations from 2010 to 2016.
Court Decision Details
The Court of Appeal in The Hague on 3 December 2025 granted the Dutch prosecutor’s “bewilligingsverzoek” to discontinue the case against Hamers, who was suspected of “factually leading” the criminal conduct. According to EFRI’s report, the court’s official press release noted that the earlier decision to open the case had already “confirmed the norm” that bank directors are not above the law, but prosecution was now halted.
Business Insurance on 4 December 2025 reported that the Hague Court of Appeal dropped further criminal proceedings against Hamers, citing NL Times and ANP, after years of investigation post the 2018 €775 million settlement and a 2020 order to probe him; prosecutors found insufficient evidence. Beinsure.com announced the Dutch court ending the bid to prosecute ex-ING CEO Ralph Hamers in the AML case, aligning with the recent appellate decision [web: provided].
Background of ING AML Scandal
ING faced massive systemic AML failures documented in the 2018 “Houston” report, allowing hundreds of millions of euros in suspicious flows through its accounts. As detailed by EFRI, repeated internal and external warnings from supervisors and auditors were not followed by timely, effective action, leading to the record settlement of €775 million – €675 million fine and €100 million disgorgement.
MoneyLaundering.com in 2021 coverage noted ING paid €775 million in September 2018 to settle AML violations from 2010-2016 that enabled organised crime syndicates and others to launder illicit funds. Reuters on 18 December 2024 reported ING’s 2018 fine of 775 million euros for failing to curb money laundering linked to customer accounts.
Prosecution’s Investigation Outcome
Dutch prosecutors concluded there was insufficient legal and convincing evidence to charge Hamers with criminal offences. Reuters quoted the public prosecutor’s statement that after extensive investigations, no charges would be filed against Hamers, who later became CEO at UBS, and he described the conclusion as “logical and just”.
AML Intelligence on 17 December 2024, as reported by Toby Sterling, stated prosecutors found not enough evidence to merit criminal charges against Hamers for failing to stop money laundering. MoneyLaundering.com on 17 December 2024 added that a four-year probe into Hamers (2013-2020) did not unearth convincing evidence for criminal responsibility, though steps taken were “insufficient” but not criminally liable.
Executive Responsibilities and Findings
Prosecutors noted that Hamers and other board members shared responsibility for compliance, but the CEO was not the only one in a “responsible position.” EFRI highlighted that ING has implemented remediation programmes under supervisory oversight since the settlement.
A 2021 disciplinary panel cleared Hamers and 14 other ING senior managers of violating the Dutch Banker’s Oath related to the AML failures, as per MoneyLaundering.com. In 2020, the Hague Court of Appeal had ordered prosecution of Hamers, but this was later reversed.
Sanctions & Enforcement Context
The decision underscores challenges in sanctions & enforcement against bank executives for AML lapses, with ING’s corporate settlement representing major sanctions & enforcement but no personal criminal accountability. EFRI warned this signals zero personal accountability in Europe’s banking sector for the €775m AML scandal.
Broader sanctions & enforcement included ABN Amro’s parallel €480 million settlement in 2021, with prosecutors also dropping cases against its ex-CEO Gerrit Zalm on 18 December 2024 for lack of evidence. These outcomes highlight ongoing sanctions & enforcement efforts through fines and remediations rather than individual trials.
Related Cases and Developments
Dutch prosecutors simultaneously dropped cases against ABN Amro executives, including Gerrit Zalm, after investigations into AML measures from 2014-2020. Reuters and MarketScreener on 18 December 2024 confirmed no charges against Zalm, mirroring the ING outcome.
Forbes Middle East recalled a 2020 Dutch court order for Hamers’ prosecution over ING’s AML non-compliance during his tenure, when the bank settled a $940 million probe. Wikipedia notes Hamers’ career progression from ING to UBS amid these events.
Implications for Banking Sector
EFRI expressed concern from the perspective of online investment fraud victims funneled through ING, viewing the outcome as a troubling signal of low accountability. They referenced a prior low €330k penalty for ex-Payvision CEO Booker as a similar precedent.
AML Intelligence quoted an expert reacting that there is “a lot of room for improvement” in the decision. The cases emphasise supervisory oversight and corporate remediations as primary sanctions & enforcement tools post-settlements.
Historical Timeline
- 2018: ING settles for €775 million over AML failures.
- 2020: Court orders Hamers’ prosecution.
- 2021: Disciplinary panel clears executives of Banker’s Oath violation.
- 2024-2025: Prosecution drops cases; court approves discontinuation on 3 December 2025.
Ralph Hamers, who led ING from 2013 to 2020, now serves at UBS. No further statements from ING or Hamers on the latest ruling were detailed in recent reports. Investigations into systemic banking AML issues continue across the Netherlands.