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MAR, REMIT

Large ING settlement for money laundering includes significant disgorgement element

The Dutch bank ING has reached a settlement with the Dutch Public Prosecution Service of €775m for failures in anti money laundering procedures and compliance, which permitted accounts to be used for criminal activity. The announcement from ING can be found here, and an article on the topic on FT.com here.

The settlement is split into a fine of €675m and a “disgorgement” amount of €100m which included amounts for the under-staffing of the compliance department, inadequate training and because “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”.

There are lessons to be learned here for anti abuse measures in general, namely that savings made by failure to invest in adequate measures will be viewed very unfavourably should they result in a compliance breach.

About avivhandler

Aviv is the Managing Director of ETR Advisory, a niche consultancy focused on the regulation of the commodity, energy and financial markets. He has more than 23 years of experience in the financial, energy and commodity markets, covering regulatory compliance, credit, risk and financial technology. Prior to founding ETR, he was Partner at SunGard Global Services, where he built a Centre of Excellence in European Energy and Commodity Regulation. Before that, he founded Coherence, a consulting firm specializing in credit risk in commodity and energy trading as well as software product management. The credit practice ultimately became part of Sirius Solutions, where he was the Managing Director of Europe. He has also held management roles at KWI and Iris Financial, among other organizations. Mr. Handler holds a degree in computer science from Imperial College, University of London.

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