ING Groep

🔴 High Risk

ING Groep N.V. is a leading Dutch multinational banking and financial services corporation with a vast global footprint and complex governance structure. Despite its prominence and robust regulatory oversight as a globally systemically important bank, ING’s history is marked by significant regulatory scrutiny, including a major fine for failing to prevent money laundering. This highlights ongoing challenges large financial institutions face in balancing expansive international operations with stringent anti-money laundering compliance. ING’s case underscores the critical importance of maintaining rigorous controls and transparency within the banking sector to mitigate risks associated with financial crime and safeguard the integrity of the global financial system.

ING Groep N.V. is a major Dutch multinational banking and financial services conglomerate with global operations and a comprehensive governance structure to oversee risk and compliance. While no direct evidence connects ING itself to active money laundering schemes or shell company abuses, regulatory sanctions (notably the 2018 €775 million fine) for insufficient AML controls have highlighted the importance of continuous vigilance in the financial sector. ING’s designation as a globally systemically important bank subjects it to rigorous European Central Bank supervision and compliance standards. Its corporate structure comprises a holding company with banking subsidiaries, governed by a two-tier board system designed to ensure oversight, risk management, and transparent reporting. ING’s role in global finance makes it a focal point for regulatory scrutiny but also a model for compliance improvement efforts. This entry reports no confirmed PEP ties or laundering cases but acknowledges the ongoing AML risk environment for any large multinational banking group.

Country of Incorporation

Netherlands

Headquartered in Amsterdam, Netherlands. Operates globally with substantial presence in Europe, the Americas, and Asia. ING has more than 40 countries of operation.

Banking and Financial Services – retail banking, direct banking, commercial banking, investment banking, wholesale banking, private banking, asset management, and insurance services.

ING Groep N.V. is a publicly listed Dutch multinational financial services corporation. It is the parent company of ING Bank N.V., the principal banking entity which itself controls various Dutch and foreign banks.
ING Groep and ING Bank have a two-tier board structure:

  • Supervisory Board (SB) – Supervises and advises with outside directors only

  • Executive Board (EB) – Responsible for management and strategy at ING Groep N.V., including CEO, CFO, and CRO

  • Management Board Banking (MBB) – Responsible for day-to-day management of ING Bank N.V.
    The corporate structure is a holding company with consolidated subsidiaries under ING Bank, including various national and international banking operations.

No publicly verified or official allegations or convictions related to laundering mechanisms were identified in the recent corporate public records or enforcement databases. However, historically, large international banks like ING are potentially exposed to risks such as:

  • Trade-based money laundering through complex trade financing

  • Layering through cross-border financial transactions

  • Potential misuse of correspondent banking or shell entities by clients
    Careful regulatory oversight is maintained due to its status as a Global Systemically Important Bank.

  • Steven van Rijswijk, CEO, Chairman Executive Board and Management Board Banking

  • Tanate Phutrakul, CFO, Member EB/MBB

  • Ljiljana Čortan, CRO, Member EB/MBB

  • Other Executive Board and Supervisory Board members are public and collectively oversee the company.
    No individual beneficial owners dominate due to public listing. Executive profiles and board composition are public, with no identified links to Politically Exposed Persons (PEPs) directly controlling.

N/A

  • No direct mention of ING Groep in major leaks such as the Panama Papers or FinCEN Files in terms of suspicious laundering.

  • ING has been subject to regulatory scrutiny historically, particularly in the context of anti-money laundering controls, with regulators emphasizing compliance improvements after past infractions unrelated to direct laundering schemes detected.

  • In 2018, ING agreed to pay a €775 million fine to Dutch authorities for failing to prevent money laundering—indicating prior weaknesses in AML controls but no explicit laundering by ING itself was alleged.

  • No open or current investigations publicly documented as of 2024.

High – Based in the Netherlands, a country with strong AML regulatory frameworks and EU supervision. However, as a globally active bank, ING faces some risk exposure based on client geography and transaction types.

  • 2018 fine by Dutch regulator DNB for AML failings totaling €775 million.

  • Ongoing supervision by the European Central Bank (ECB) under the Single Supervisory Mechanism as a significant financial institution.

  • Listed on multiple stock exchanges including Euronext Amsterdam, Brussels, and American Depositary Receipts on the New York Stock Exchange subject to U.S. regulatory oversight.

  • No blacklisting or sanctions on the entity itself.

  • Periodic regulatory compliance demands and governance reviews documented in annual reports.

Active – Listed, operational, and under regulatory supervision.

  • 1991: ING Group established through merger of Dutch insurance and banking entities.

  • 2002–2014: Operated head office at ING House in Amsterdam Zuidas business district.

  • 2012: ING Bank became member of the global systemically important banks list.

  • 2018: Paid €775 million fine for AML compliance failings, a significant regulatory action.

  • 2020: Operated in over 40 countries with 53.2 million clients globally.

  • 2023: ING Groep N.V. updated articles of association; firm remains under strong governance and ECB prudential supervision.

  • Continuous corporate governance and AML control strengthening ongoing.

None confirmed (potential risks in trade finance)

EU, Global Operations (Americas, Asia)

High (due to global footprint and AML compliance history)

ING Groep N.V.

ING Groep
Country of Registration:
Netherlands
Headquarters:
Amsterdam, Netherlands (Bijlmerdreef 106, Amsterdam, 1102CT)
Jurisdiction Risk:
High
Industry/Sector:
Banking and Financial Services
Laundering Method Used:

No officially confirmed methods; potential risks in trade finance, layering, correspondent banking

Linked Individuals:

Steven van Rijswijk (CEO), Tanate Phutrakul (CFO), Ljiljana Čortan (CRO), no confirmed PEPs

Known Shell Companies:

None publicly identified

Offshore Links:
Estimated Amount Laundered:
Not applicable; no confirmed laundering figures
AML Network Risk Rating:
🔴 High Risk
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