Issue #18 | August 25, 2026 | 7 min read
The Brief
ING's €775 million settlement is usually filed under the same header as every other bank AML case: institution pays, no individual answers for it. ING's case broke that pattern, just not in the way you'd expect. A Dutch court didn't just criticize the lack of personal accountability, it ordered prosecutors to charge the bank's own CEO. It took five more years for that order to collapse into nothing.
This issue covers what regulators found inside ING's accounts, and what happened when a private citizen forced prosecutors to answer a question they'd already decided to leave alone.
Main Feature
A Court Ordered ING's Former CEO Prosecuted. Prosecutors Spent Five Years Failing to Make It Stick.
The bank settled without a conviction. The case against the man running it while the violations occurred took a very different, and much longer, path to the same result.
In September 2018, ING Bank accepted a €775 million settlement with the Netherlands Public Prosecution Service: a €675 million fine plus €100 million in disgorgement. It was, and still is, the largest financial settlement in Dutch history. Prosecutors found that between 2010 and 2016, ING structurally and repeatedly violated the country's anti-money laundering law, failing at what regulators call its gatekeeper duty. The bank accepted the settlement rather than face prosecution itself, so there was no guilty plea and no criminal conviction attached to the institution.
The investigation described specific, structural gaps: an absence of, or insufficient, client due diligence; clients misclassified into the wrong risk segment; account monitoring that generated, in the prosecutor's own words, only a limited number of money laundering signals relative to the volume running through the bank; and a compliance department that was both understaffed and inadequately trained. Two of the illustrative cases regulators cited show what that looked like in practice. A telecom company moved bribes worth tens of millions of dollars through its ING accounts to a company owned by the daughter of the president of Uzbekistan; ING neither verified who actually owned that company nor reported the activity until it was far too late to matter. Separately, a lingerie trading business ran roughly €150 million through its ING accounts. The bank's own monitoring system did flag the activity as unusual. Compliance staff dismissed those alerts as "not unusual," in the prosecutor's phrasing, without meaningfully investigating them first. Two smaller examples rounded out the case file: a one-man building materials business moved €9 million partly through mobile currency-exchange ATMs in Suriname, a use explicitly barred by ING's own account rules, and two connected shell-like import companies deposited more than €500,000 in cash over a year with only one deposit ever flagged.
€775M — total ING settlement, September 2018: €675M fine + €100M disgorgement
2010–2016 — period of structural AML Act violations found by Dutch prosecutors
€150M — moved through one lingerie trading client's ING accounts; the bank's system flagged it, compliance dismissed the alerts
5 years — from the court order to prosecute ING's former CEO (Dec 2020) to the case being formally dropped (Dec 2025)
The settlement resolved the institution's exposure. It didn't resolve the question of who, personally, was responsible for the policy that let it happen and that question didn't stay closed. Ralph Hamers was ING's CEO for most of the violation period. Prosecutors initially decided not to charge him. A Dutch financial activist, Pieter Lakeman, challenged that decision through a legal procedure that lets a private complainant force judicial review of a prosecutor's choice not to prosecute. In December 2020, the Hague Court of Appeal sided with him, ruling there was sufficient basis to prosecute Hamers for "feitelijk leidinggeven," roughly translated as acting as the de facto leader of the criminal conduct. The court didn't hedge: it found Hamers wasn't merely aware of the bank's failing AML policy, he had actively participated in shaping it. Years of investigation followed. In December 2024, prosecutors announced they still wouldn't bring charges, citing insufficient evidence. This past December, the Hague Court of Appeal granted prosecutors' request to close the matter entirely, citing the burden the years-long proceeding placed on court and prosecutorial resources, and Hamers's own private interest in finally putting it behind him.
Red flags in this case
Wire activity from a corporate client to an account beneficially owned by a politically exposed person's relative, with ownership verification completed late or not at all
A transaction monitoring system correctly generating an alert, followed by staff dismissing it as "not unusual" with no documented investigation behind that call
A client's account volume with no plausible connection to its stated line of business (a lingerie importer moving nine figures)
A business client operating outside a use case explicitly barred by the bank's own account terms
Structured cash deposits across linked accounts, with only a fraction of activity ever generating a suspicious activity report
If you work anywhere near personal liability exposure for compliance leadership, the Hamers case is worth reading closely, not for the outcome but for what it took to even get that far. A Dutch appeals court found enough evidence to order a criminal prosecution of a sitting former CEO under a legal theory that required proving he didn't just tolerate a failing policy, he helped build it. That case still took five years and ended without charges ever being formally filed. Institutional settlement admissions, the kind ING signed in 2018, don't automatically translate into evidence a prosecutor can use against a named individual. The paper trail that actually matters for personal liability is different: who signed off on the policy, who saw the alert volume and left it understaffed anyway, who was told the monitoring system wasn't catching enough and didn't change it.
ING got its bill and moved on. The man running the bank while that bill accrued got five more years of litigation and, in the end, a clean record.
Source: Netherlands Public Prosecution Service (Openbaar Ministerie), "ING pays 775 million due to serious shortcomings in money laundering prevention," September 4, 2018 | Gerechtshof Den Haag (Hague Court of Appeal), Article 12 ruling ordering prosecution of Ralph Hamers, December 2020 | NL Times, reporting on the Public Prosecution Service's December 2024 decision not to prosecute and the Hague Court of Appeal's December 3, 2025 order ending further prosecution
Intelligence Briefing
Treasury/OFAC — On August 20, Treasury designated ten individuals in a courier network that moved cash for Hizballah on commercial flights between Lebanon, Türkiye, the UAE, and Iran, using bulk-cash smuggling to move funds outside the formal financial system and avoid the same sanctions that block Hizballah's banking access. OFAC also re-designated Hizballah itself for acting under IRGC-Qods Force direction. Source: U.S. Department of the Treasury, "Treasury Increases Sanctions on Hizballah and Targets Network Smuggling Millions in Cash for Hizballah," August 20, 2026.
DOJ — On August 18, a member of a Chinese money laundering organization was sentenced to 15 years in prison and ordered to forfeit $25 million for laundering more than $92 million in illicit proceeds, including funds from drug trafficking, through the organization's network. The case is part of DOJ's continuing enforcement focus on Chinese underground banking networks that launder cartel drug proceeds for a fee, without ever physically moving cash across the border. Source: DOJ, "Prolific Chinese Money Launderer Sentenced to 15 Years in Prison for Laundering Drug Trafficking Proceeds Following Homeland Security Task Force Investigation," August 18, 2026.
Career Intel
BLS puts the median compliance officer salary at $78,420 (May 2024), a line-level figure that says nothing about what the job actually carries at the MLRO or CCO level. This issue's main case is a reminder of the gap: the title that comes with real personal liability exposure, the one a court can order prosecuted, sits well above that median, and the compensation, D&O coverage, and legal indemnification attached to it should scale with that exposure, not just with headcount managed.
Open Roles
In partnership with Artha. If you apply through a listing below, we may earn a commission at no cost to you. We only pick roles we'd tell a colleague to apply for.
Role | Company | Location | Apply |
|---|---|---|---|
Enhanced Due Diligence Analyst | Nicolet National Bank | West Des Moines, Iowa | |
Analyst, Aml Compliance | Western Union | Denver, CO | |
Fraud Analyst | Northwest Bank | Columbus, OH | |
Compliance Testing Analyst | Old National Bank | Indianapolis, IN | |
Compliance Analyst | TEKsystems | Houston, TX |
Tip Line
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Disclaimer: The AML Brief is an independent financial crimes intelligence publication. All content is sourced from publicly available regulatory documents, enforcement actions, and published research. Nothing published here constitutes legal, compliance, or regulatory advice. The AML Brief is not affiliated with any financial institution, regulator, law firm, or employer. For advice specific to your situation, consult a qualified attorney or compliance professional.