Dutch prosecutors hammered ING Group for 7+ years of abject AML failures … missing and incomplete customer due diligence files, failing to review CDD files, improper customer risk ratings, failure to exit known bad customers in a timely fashion, late suspicious transaction reports, capping transactional alerting systems (which they called “topping”), even “culpable money laundering.” ING failed to adequately staff its financial economic crime group, knew it was understaffed, and didn’t properly staff it. The Dutch prosecutors seemed irritated about this, as they imposed a EUR 100,000,000 “disgorgement” based on the amount that ING under-staffed its FEC unit by.
Expect much industry fall-out from this. It raises the penalty bar to new heights – no European agency has imposed a fine and penalty even close to this.