Base errors: the ING case

Denis O’Connor is a Fellow of both the Institute of Chartered Accountants in England & Wales and the Chartered Institute of Securities and Investment. He was a member of the British Bankers’ Association Money Laundering Committee from 2003-10 and a member of the Joint Money Laundering Steering Group’s Board and Editorial Panel between 2010 and 2016. He has been a frequent speaker at industry conferences on financial crime issues, both in the UK and abroad.

Financial crime staff would be welladvised, says Denis O’Connor, to carefully review the recently published Statement of Facts [1] agreed between ING Netherlands and the Netherlands Public Prosecution Service following a criminal investigation into the bank’s anti-money laundering controls which cost it €775 million in an out of court settlement. In the meantime, his own close reading of the document provides an instructive digest.