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ING Group

ING Groep N.V. is a Dutch multinational banking and financial services corporation headquartered in Amsterdam. Formed in 1991 through the merger of insurer Nationale-Nederlanden and banking group NMB Postbank Groep, it operates retail and wholesale banking services in more than 100 countries, employing over 60,000 staff. As of mid-2024, ING manages total assets of €1,041 billion. The company pioneered branchless online banking with the launch of ING Direct in 1997, expanding this model internationally and influencing the shift toward digital financial services. It has grown through acquisitions, such as Barings Bank in 1995 following its collapse, and later divested non-core insurance operations, including the 2014 demerger of NN Group to focus on banking. ING ranks among the world's largest banks by assets and has received recognition for sustainable finance initiatives, though it maintains involvement in sectors like defense funding aligned with national security needs. Notable controversies include a 2018 settlement of €775 million with Dutch authorities for systemic shortcomings in anti-money laundering controls, which allowed criminal activity through its accounts over years. More recently, ING faces litigation from environmental groups alleging inadequate due diligence on climate risks in its lending practices. These events underscore ongoing regulatory pressures in an industry prone to compliance challenges, despite ING's efforts to enhance risk management systems post-settlement.

History

Origins in Insurance and Banking

The insurance heritage of ING Group originated with De Nederlanden van 1845, established on April 12, 1845, in , , by cousins Gerrit Jan Dercksen and Christiaan Henny as a fire company named Assurantie-maatschappij tegen Brandschade. This entity initially focused on insuring against fire and other property risks, expanding over time to include and pensions. In 1863, the Nationale Levensverzekering-Bank was founded in by William Siewertsz van Reesema and Simon van der Heldt, specializing in policies. These two companies merged in 1963 to form Nationale-Nederlanden, which grew into one of the ' largest insurers by combining property, casualty, and operations. ING's banking roots stem from the Nederlandsche Middenstandsbank (NMB), founded in through the merger of several regional banks aimed at serving small businesses and the , including the Algemeene Nederlandsche Centrale Middenstandsbank, Hanzebank, Bank, and Middenstandsbank voor en Omstreken. NMB developed into a with a focus on and corporate lending, establishing a network across the and international branches. Complementing this was Postbank, which evolved from the postal savings and system initiated in the for public deposits and payments; it was privatized and incorporated as Postbank N.V. in 1986, serving 7.5 million account holders primarily through postal outlets. In the same year, NMB merged with Postbank to create NMB Postbank Groep, integrating with mass-market services. These insurance and banking entities laid the foundation for ING by combining complementary strengths in and deposit-based lending, reflecting the Dutch tradition of specialized financial institutions adapting to economic needs. Prior to their 1991 consolidation, Nationale-Nederlanden and NMB Postbank Groep operated as independent pillars, with the former emphasizing long-term savings products and the latter prioritizing accessible transaction banking.

Formation and Early Mergers

In 1989, Nederlandsche Middenstandsbank (NMB Bank), a focused on small and medium-sized enterprises, merged with Postbank N.V., the privatized former postal with a large base, to create NMB Postbank Groep N.V. The merger, finalized on October 4, combined NMB's corporate banking expertise with Postbank's extensive network of over 7.5 million private account holders and government-backed stability, forming one of the ' largest banking entities at the time. This banking group then merged with the company Nationale-Nederlanden on March 4, 1991, establishing Internationale Nederlanden Groep N.V. (ING Group). Nationale-Nederlanden, itself recently formed in 1989 from the combination of De Nederlanden van 1845 and Nationale Levensverzekering-Bank, brought a strong life and non-life portfolio to the , creating a diversified financial conglomerate with combined assets exceeding those of many European peers. The new entity's name reflected its international ambitions, though initial operations remained centered in the Netherlands. Following the merger, ING Group was listed on the Amsterdam Stock Exchange (now ) in March 1991, enabling public trading and capital raising for expansion. This structure integrated banking and under a single , a model that positioned ING for opportunities but also introduced complexities in regulatory oversight and during the early 1990s European financial integration.

International Expansion and Acquisitions

Following its formation in 1991 through the merger of Nationale-Nederlanden and NMB Postbank Groep, ING Group pursued aggressive international expansion via acquisitions to build capabilities in banking, insurance, and wholesale finance beyond the Netherlands. This strategy targeted established institutions in mature markets and emerging opportunities in Central Europe and Asia, leveraging synergies between retail, commercial, and investment operations. By the late 1990s, ING had established a multinational footprint, with acquisitions enhancing its wholesale banking in the UK and Asia while bolstering insurance in North America. A pivotal early move occurred in 1995, when ING acquired the collapsed for a symbolic £1 after massive derivatives losses led to its failure; this provided ING with Barings' global network, including key hubs in for and operations in and that strengthened its Asian wholesale presence. The deal, though initially tarnished by the , integrated Barings' expertise in emerging markets and fixed-income trading, contributing to ING's diversification into higher-margin activities. In 1997, ING expanded into the U.S. by acquiring Equitable of Companies, a provider, for $2.2 billion, which elevated its position in the American defined-contribution and markets and marked one of its largest cross-border insurance deals at the time. The same year, ING launched its ING Direct brand, initially in the UK and , enabling low-cost retail entry into competitive markets without physical branches; this model later scaled to the U.S. in 2000 and in 1999, attracting millions of customers through high-yield savings products. Concurrently, ING secured a controlling stake in 's Banque Bruxelles (BBL) starting in 1997, achieving full ownership by 2000 through a merger that created ING and solidified retail and corporate banking in . Expansion into gained momentum in the early 2000s, with ING acquiring a majority stake in Poland's Bank Śląski in 2001, enhancing its retail and SME lending in a high-growth market post-EU accession preparations. In , ING bolstered its footprint in 2000 by purchasing Aetna's businesses, adding and retirement products across the region and supporting organic growth in countries like and through joint ventures. These moves diversified revenue streams amid European regulatory changes and positioned ING for emerging market scale. By 2007, ahead of the global financial crisis, ING further extended into the and emerging Europe by acquiring Turkey's Oyak Bank for $2.673 billion, gaining 300 branches and a strong corporate client base in a dynamic ; the deal, accretive to earnings from , reflected ING's appetite for bolt-on acquisitions in underserved segments. Overall, these acquisitions—totaling dozens in the and —doubled ING's international exposure, though they also increased complexity and risks that later necessitated .

Global Financial Crisis and Government Intervention

During the 2008 global financial crisis, ING Group faced significant pressures from its exposure to U.S. mortgage-backed securities, resulting in substantial losses that strained its capital position and liquidity. Despite being described as fundamentally healthy, the bank encountered difficulties accessing capital markets amid widespread credit freezes, prompting government action to prevent broader instability. On October 9, 2008, the Dutch government announced €20 billion in potential support for viable to stabilize the sector. ING became the first to utilize this facility, receiving a €10 billion capital injection on October 19, 2008, structured as core securities issued to the state without voting rights. This intervention aimed to bolster ING's ratio to approximately 8% and restore market confidence, with the government acquiring a 10% indirect stake equivalent. In January 2009, amid ongoing market turmoil, ING secured additional assistance through the Illiquid Assets Back-up Facility (IABF), under which the assumed 80% of the risk on a portfolio of approximately €27.7 billion in illiquid U.S. residential mortgage-backed securities. The facility, finalized with risk transfer effective , 2009, included an option for ING to repurchase the protected assets after three years at a premium, providing a backstop against further writedowns while requiring the bank to divest non-core operations as a condition. These measures, totaling around €10 billion in core support plus the IABF guarantee, enabled ING to navigate the crisis without immediate insolvency, though they imposed ongoing regulatory scrutiny from the .

Restructuring and Divestitures Post-Crisis

Following the 2008 global financial crisis, ING Group received €10 billion in state from the Dutch government, comprising a €10 billion capital injection in November 2008 and guarantees on US Alt-A mortgages in January 2009. The approved ING's initial restructuring plan on November 18, 2009, mandating the separation of its banking and insurance operations, divestiture of non-core assets to reduce and repay the , and restrictions on to restore viability without distorting competition. This plan was amended in November 2012 to extend divestment timelines and increase flexibility amid challenging market conditions, with commitments to repay remaining capital by 2015. A cornerstone of the restructuring was the separation of ING's insurance and businesses. On October 26, 2009, ING announced plans to fully divest these units, culminating in the creation of N.V. as the legal successor to ING's insurance operations effective March 2014. launched its on on July 2, 2014, with ING selling 77 million shares at €20 each, raising approximately €1.54 billion. ING progressively reduced its stake through follow-on offerings, achieving IFRS deconsolidation of on May 26, 2015, after selling down to 42.4%, thereby fulfilling key requirements. The final divestment occurred on April 14, 2016, with the sale of ING's remaining 14.1% stake in for €457 million. Significant banking divestitures included the sale of ING Direct USA, its online banking unit with $95 billion in deposits, to Financial Corporation. Announced on June 16, 2011, for $9 billion (€6.3 billion), the transaction closed on February 17, 2012, helping ING meet EU-mandated reductions in retail banking presence. In the insurance sector, ING divested its operations through , Inc. (formerly ING U.S.), completing the sale of its remaining 45.6 million shares for approximately $2 billion in March 2015. Other notable exits encompassed the 2010 sale of three broker-dealer units comprising 75% of ING Advisors Network to a led by Lightyear Capital, generating $65 million; the 2013 divestment of ING's Thai insurance and banking operations to for $128 million; and sales of Asian insurance arms, including in and ING's stake in ING Funds in . Between late 2008 and early 2014, ING executed 31 divestments across various countries, generating proceeds that facilitated full repayment of the €10 billion state aid plus €3 billion in interest and premiums by December 2014. In 2013, ING reached an agreement with the to accelerate completion of the restructuring to the end of , two years ahead of the amended schedule, with substantial progress by mid-2015 allowing focus on core retail and . These measures restored ING's standalone viability, reduced its by over €200 billion in non-core assets, and positioned it as a pure banking entity by .

Business Operations

Retail Banking

ING's Retail Banking division delivers to individual customers, small and medium-sized enterprises (SMEs), and mid-corporate clients, emphasizing primary banking relationships where customers consolidate their activities with the institution. The division operates a digital-first model, prioritizing and online channels to provide accessible, efficient services across its markets. Products encompass current and savings accounts, mortgages, personal and business loans, investment options, and payment solutions, tailored to local regulations and customer needs in most operating regions. The division maintains a presence in key European markets such as the , , and , alongside challenger markets including , , , and , with selective activities in . These markets are categorized internally as leaders, challengers, and growth areas to guide and expansion strategies. In the , for example, includes business lending and consumer products integrated with daily banking operations. As of the second quarter of 2025, more than 41% of customers selected ING as their primary bank, reflecting success in deepening relationships through targeted offerings. Digital initiatives form the core of Retail Banking's competitive edge, with heavy investment in technology to enhance customer experience and operational efficiency. ING has deployed generative AI-powered chatbots for personalized support and introduced features like instant app verification to combat fraud and digital overdraft protections for business clients. This approach drove a 1.1 million increase in mobile primary customers during the first half of 2025, alongside net inflows of €8.9 billion in customer deposits in the second quarter alone. The strategy supports sustained growth in lending and deposits, positioning Retail Banking to adapt to evolving consumer preferences for seamless, technology-enabled services.

Wholesale Banking

ING's Wholesale Banking division provides specialized financial services to large multinational corporations, financial institutions, and other institutional clients, focusing on lending, services, and capital markets solutions across more than 35 markets primarily in , , the , and the . It emphasizes sector-specific expertise in areas such as , manufacturing, technology, and trade, combining local market insights with global capabilities to deliver tailored solutions including and . The division operates through an international network of offices in over 40 countries, enabling it to support cross-border activities for clients with complex needs. Wholesale Banking is organized into four primary business lines: Industry Lending, which finances sector-specific projects and operations; General Lending and Transaction Services, covering solutions, payments, and ; Financial Markets, offering and capital raising, hedging, and trading services; and a dedicated banking segment for institutional counterparts. Services extend to functions like payments and , alongside advanced offerings such as multi-bank cash pooling and digital onboarding platforms now available in eight countries with plans for further expansion. This structure supports non-lending revenue streams, which ING aims to increase to approximately 67% of wholesale income over the long term from around 50% in 2023, driven by growth in and advisory. In 2024, reported a gross result of €3,423 million, reflecting resilient from expanded lending and deposits amid investments in front-office capabilities and strong in Financial Markets. The division has prioritized and client-centric innovations, such as next-generation payments solutions for multi-bank environments, to enhance efficiency and competitiveness in a recovering landscape.

Digital and Direct Banking Initiatives

ING has prioritized as a core component of its operations since the early , establishing itself as one of Europe's largest banks with a focus on seamless, anytime-accessible services for individual and customers. The bank's Think Forward strategy, launched in 2016, allocated €800 million toward , emphasizing and payments innovation to enhance and efficiency. This included a shift to agile organizational models inspired by tech firms like , implemented starting in 2015, which restructured teams into "squads" and "tribes" to accelerate product development. Central to these efforts is the ING Banking , available on and platforms, which enables users to manage accounts, execute payments, monitor transactions, control cards, and access features like cashbacks, notifications, and options in . As of 2025, the app supports over 146,000 reviews with a 4.5-star average rating on , reflecting high adoption rates, particularly among mobile-primary customers in retail segments. ING reported growing usage in Q1 2025, alongside launches of three new digital features aimed at improving personalization and security, such as and enhanced PIN management in commercial card apps. In direct banking, ING maintains branchless models in select markets, notably , where it operates as a since 1999, offering no-physical-branch services via online and mobile channels exclusively. This approach extends to innovations like generative -powered chatbots for , developed in with McKinsey's QuantumBlack in recent years, prioritizing user-centric interactions over traditional call centers. The bank has also pursued a cloud-first and acceleration, investing in cross-border digital capabilities while navigating generational differences in client tech adoption across . These initiatives supported a 2018 update that involved cutting 7,000 jobs to reallocate resources toward digital scaling, underscoring a commitment to cost efficiency amid competitive pressures.

Global Presence

Operations in Europe


ING Group's core operations are concentrated in , where it delivers retail and wholesale banking services through its operating entity, ING Bank N.V., headquartered in , . The bank's European footprint encompasses key retail markets in the , , , and other countries including , , , , and . Wholesale banking extends to over 20 markets in the region, facilitating corporate financing, trade, and capital markets activities.
In , ING reported robust growth in 2024, with net core lending expanding by €28 billion (4%) across its European segments, driven primarily by €19 billion in mortgage originations, particularly in and the . Net core deposits increased by €47 billion (7%), reflecting strong customer acquisition and retention. Mobile primary customers grew by 1.1 million to 14.4 million, with notable expansions in , the , , and . These operations are segmented into Retail , Retail , Retail , and Retail Other, which collectively form a substantial portion of ING's , estimated at around half from its primary European markets. Wholesale banking in supports multinational corporations, financial institutions, and mid-sized enterprises with services such as lending, , and sustainable financing solutions. In 2024, this segment contributed to overall fee income growth exceeding 11%, bolstered by capital markets activities. has pursued strategic exits, including the sale of its Russian business to Global Development JSC in 2025, amid geopolitical considerations. Concurrently, as of February 2025, the bank expressed interest in acquisitions to enhance its scale in , , and .

Operations in Asia and Australia

ING's operations in and are predominantly focused on , serving multinational corporations, financial institutions, and needs across 11 markets, including , , SAR, , , , the , , , , and . The region hosts ING's largest branch network in , employing over 300 financial experts with coverage extending to key financial centers such as , , , and . In October 2024, ING appointed Uday Sareen as head of for to oversee strategy and performance in these markets. In China, ING holds a 13% stake in Bank of Beijing and operates branches in major cities, emphasizing corporate lending and initiatives. The bank has prioritized and solutions, adapting to regional shifts away from China-centric models toward diversified digital partnerships amid geopolitical fragmentation. Retail banking activities in Asia have been limited and subject to divestitures; for instance, ING wound down its retail operations in the Philippines by the end of 2022 to streamline its focus on wholesale segments. Sustainable financing has been a growth area, including a $75 million to Singapore-based Cleantech Solar in July 2020 for clean energy projects in . In Australia, ING operates both retail and wholesale banking through its wholly owned subsidiary, ING Bank (Australia) Limited, which provides direct banking services, home loans, and savings products to over 1.4 million customers as of 2024. The subsidiary traces its roots to earlier expansions but underwent significant restructuring post-2008 , including the sale of its 51% stake in ING Australia insurance operations to ANZ in November 2009 and the divestiture of its unit to in June 2011. Wholesale activities include project financing, such as the 100 MW Clare Solar Farm in funded in November 2017, marking one of ING's early deals in the country. As of 2025, ING continues to integrate digital innovations and sustainable lending in , aligning with broader priorities.

Other International Activities and Exits

ING maintains operations , servicing domestic and international corporates as well as institutional clients through offices in , , , and , though it lacks a and thus does not engage in deposit-taking activities. In , ING operates a full-service and corporate banking presence established over nearly 30 years, with 207 branches nationwide and a focus on serving individual and business customers through products like loans, deposits, and investment services. ING exited the Canadian market in 2009 by divesting its 70% stake in ING Canada, its insurance operations, through a valued at approximately $2.2 billion, followed by the sale of its remaining 7% holding. Separately, ING Direct Canada, its unit, was sold to as part of broader post-crisis restructuring. In the , ING sold its ING Direct to in February 2012 for $9 billion, comprising $6.2 billion in cash and approximately 55.9 million shares in , marking the end of its presence there. In , ING divested its , pension, savings, and investment management operations across , , , , , and to Colombia's Grupo Sura in July 2011 for US$3.85 billion, aligning with regulatory requirements to shed non-core assets following bailouts. Regarding , ING ceased new business in 2022 amid geopolitical tensions and announced the sale of ING Bank () JSC to local firm Global Development JSC in January 2025; however, as of September 2025, the transaction remains pending regulatory approvals, with ING having reduced its exposure to Russian clients by over 85% to €0.7 billion. These exits reflect ING's strategic refocus on core and select international wholesale activities post-global .

Financial Performance

ING Group's total assets expanded significantly in the early through acquisitions and , rising from $623.8 billion in 2001 to a peak of $1.916 trillion in 2007, driven by expansions in banking and operations across and beyond. This period reflected aggressive international diversification, including the integration of entities like Bank of Montreal's European retail operations in 1997 and subsequent deals. However, the 2008 global financial crisis severely impacted performance, with market turmoil leading to substantial impairments and a full-year net loss, exacerbated by declines in and activities while banking remained partially resilient. In response, ING received €10 billion in Dutch state aid, comprising a capital injection and guarantees, which stabilized operations but mandated restructuring under state aid rules. The post-crisis restructuring from 2009 to 2014 involved extensive divestitures—31 in total—to repay the aid fully by November 2014 and refocus on . This led to a contraction in total assets, dropping from $1.857 trillion in 2008 to $1.652 trillion in 2010 and further to $888.89 billion by 2016, primarily due to the sale of arms like ING Insurance Americas and . Profitability began recovering, with an underlying net profit of €748 million in 2009 (versus a net loss of €935 million) and €3.893 billion in 2010, supported by cost controls and banking segment strength. By the mid-2010s, assets stabilized around $1 trillion, reflecting a shift to higher-return retail and in , with selective international presence.
YearTotal Assets (USD)Net Profit (EUR, underlying where noted)
2008$1.857 Net loss (specific figure not detailed in results; crisis-driven impairments)
2010$1.652 €3.893 billion (underlying); €3.220 billion (reported)
2015$1.099 Fluctuating recovery post-divestitures
2020$1.152 Positive amid challenges
2024$1.108 $5.772 billion (approx. €5.3 billion equivalent)
In the late and early , financial trends showed steady asset growth and improved profitability, with total assets surpassing $1 trillion by 2018 and reaching $1.108 trillion in 2024, fueled by deposit inflows, lending expansion in key markets, and digital efficiencies. experienced volatility—e.g., a decline in 2023 due to higher provisions—but overall trended upward, reflecting resilience in interest income amid rising rates and a customer-centric model. This recovery underscored causal links between divestiture-driven de-risking and sustained banking-focused returns, though legacy exposures to regulatory fines occasionally pressured margins.

Recent Earnings and Shareholder Returns (2020-2025)

ING Group's net result for the full year 2020 was €2,485 million, reflecting impacts from the including elevated loan loss provisions and adherence to regulatory restrictions on distributions. Earnings recovered in subsequent years amid rising interest rates, which boosted across retail and segments. The group reported a profit before tax of €2,369 million in the second quarter of 2025, supported by stable fee income and cost discipline, though facing headwinds from currency fluctuations and moderating liability margins. Shareholder returns during this period emphasized progressive dividends and share repurchases once regulatory constraints eased post-pandemic. No dividends were paid in 2020 in compliance with recommendations prohibiting distributions from March 2020 to September 2021. Dividends resumed in 2021 at €0.60 per share, increasing to €0.81 in 2022, €0.82 in 2023, €1.11 in 2024, and €1.22 projected for 2025, reflecting a targeting 50% of net profit distribution above a profitability hurdle. Share buybacks were suspended during the early but restarted thereafter, with notable programs including a €2 billion repurchase completed in April 2025 and an additional €2 billion announced in October 2024 for completion by April 2025, alongside cash dividends totaling up to €2.5 billion in distributions for 2024. These actions, combined with share price appreciation from pandemic lows around €6 to over €20 by late 2025, delivered a five-year shareholder return of approximately 347%, outperforming broader benchmarks.
YearDividend per Share (€)Key Buyback Activity
20200.00Suspended
20210.60Resumed post-ECB
20220.81Ongoing programs
20230.82Expanded
20241.11€2B completed
20251.22 (proj.)€2B in progress

Leadership and Governance

Executive Board Structure

The Executive Board of ING Groep N.V. serves as the statutory managing body, responsible for the company's overall management and the establishment of its long-term strategy, under the supervision of the . It comprises three members: the (CEO), who acts as chairman, the (CFO), and the (CRO). This compact structure ensures focused leadership on strategic oversight, distinct from the operational responsibilities handled by the larger Management Board Banking for ING Bank N.V. As of October 2025, the Executive Board consists of Steven van Rijswijk as CEO and chairman since July 2020, Tanate Phutrakul as , and Ljiljana Čortan as . Van Rijswijk, who joined ING in 1995, oversees the group's direction; Phutrakul manages financial strategy; and Čortan directs frameworks. On 22 October 2025, ING announced that Ljiljana Čortan will transition from CRO to Head of Wholesale Banking, a role on the Management Board Banking, effective no later than the 2026 Annual General Meeting in April, succeeding Andrew Bester; she will step down from the Executive Board upon this change, with a search underway for a new CRO subject to regulatory approval.

Key Leadership Changes and Strategies

Steven van Rijswijk succeeded as (CEO) and chairman of the Executive Board and Management Board Banking on July 1, 2020, following Hamers' departure to lead UBS's operations. Van Rijswijk, who joined ING in 2002 and had served as head of and a member of the Executive Board since 2017, prioritized continuity in the bank's digital-first model while navigating post-pandemic recovery and regulatory pressures. Under van Rijswijk's leadership, ING has emphasized two strategic pillars: delivering superior customer value through personalized digital services and integrating into core operations, including commitments to phase out financing by 2040 and allocate €75 billion to sustainable projects by 2025. The bank has pursued by streamlining processes, investing in technology for a digital-only model in select markets, and focusing growth on high-return segments like wholesale and business banking in and Asia. Recent Executive Board adjustments include the appointment of Ljiljana Čortan as head of , effective no later than the 2026 , succeeding Andrew Bester who is retiring after leading the division since 2017. In July 2025, Nadine Klokke was named global head of Business Banking, returning from competitor Knab to drive client-focused innovations in SME lending. Tanate Phutrakul announced his departure for 2026, signaling a planned to maintain strategic stability amid emphasis on integration and long-term . These changes aim to bolster and client coverage while advancing ING's goal of 8-10% annual through disciplined capital allocation.

Controversies and Regulatory Issues

Money Laundering Investigations and Fines

In September 2018, ING Netherlands reached a settlement with the Dutch Public Prosecution Service, agreeing to pay a total of €775 million—comprising €675 million in penalties and €100 million in disgorgement—for systemic failures in anti-money laundering (AML) controls between 2010 and 2016. The investigation identified deficiencies in client due diligence, transaction monitoring, and suspicious activity reporting, which allowed potential money laundering indicators—such as structured deposits and unusual fund transfers—to go undetected, enabling criminals to launder funds through ING accounts. ING fully cooperated with authorities, implemented remedial measures including enhanced AML systems, and faced no further criminal prosecution as part of the agreement, though the settlement acknowledged the materialization of identified risks. Subsequent to the settlement, Dutch prosecutors pursued individual accountability, initiating proceedings against former ING executives, including CEO , for oversight failures related to the AML lapses. However, in December 2024, these criminal cases were dropped due to insufficient evidence of personal culpability, with authorities citing challenges in proving intent amid the bank's cooperative stance and internal reforms. The 2018 penalty prompted shareholder litigation, including a proposed alleging breaches of duty in , though outcomes remained pending as of early 2025. In March 2025, Spain's Executive Service for the Commission for the Prevention of and Monetary Offences (SEPBLAC) imposed a €3.91 million fine on ING's branch for a "very serious" AML , stemming from failures to investigate and report suspicions of in customer transactions. The violation involved inadequate follow-up on red flags, contravening Spain's AML regulations, with regulators emphasizing the need for proportionate deterrence. ING's payment services subsidiary Payvision, acquired in 2017, faced a separate Dutch criminal probe starting around 2019 into alleged AML and counter-terrorism financing violations, including facilitation of high-risk merchant processing. In April 2024, former Payvision executives were fined by the Prosecution Service for structural non-compliance, but ING Group itself incurred no direct penalty, instead recording impairments exceeding €360 million and contributing to ongoing civil claims. The highlighted gaps in oversight of third-party flows, prompting ING to wind down Payvision operations by 2023. In January 2024, environmental nonprofit Milieudefensie (Friends of the Earth Netherlands) announced plans to sue ING Groep NV and ING Bank NV, alleging the bank's financing of fossil fuel expansion and high-emission industries contributes to dangerous climate change by failing to align with Dutch duty-of-care laws under the Civil Code. The lawsuit, formally filed on March 28, 2025, demands ING align its financed emissions with the Paris Agreement's 1.5°C target, including halving absolute financed emissions by 2030 from a 2023 baseline and ceasing support for companies developing new oil and gas fields. Critics, including Milieudefensie, claim ING underreports its exposure to new oil and gas development by a factor of ten, with a February 2025 report estimating ING's actual financing at €10.6 billion since 2016, compared to the bank's self-reported €1 billion. ING has faced accusations of greenwashing from activist groups, including a 2018 protest in where demonstrators criticized the bank's claims amid continued lending. In June 2023, the Advertising Code ruled ING's promotional video on its misleading, as it omitted ongoing financing details. ING responded that its disclosures comply with international standards like the Task Force on Climate-related Financial Disclosures (TCFD) and defended its reporting methodology against the underreporting claims. The bank announced tightenings, such as ending general financing for pure-play upstream oil and gas explorers developing new fields in October 2024 and restricting new LNG export terminals from 2026, though NGOs expressed mixed reactions, arguing these measures exclude downstream and support. On deforestation, ING has drawn criticism for investments in palm oil firms linked to habitat loss and human rights issues, notably Belgian-Luxembourgish company SOCFIN, which operates plantations accused of illegal land grabs and evictions in Africa and Asia. A 2022 BankTrack report highlighted ING's continued exposure to such sectors despite its 2019 deforestation policy prohibiting ties to illegal logging or high-conservation-value forest clearance. ING updated its stance in October 2023 to enhance due diligence, including traceability requirements for commodities like soy and palm oil, but has not fully divested from criticized clients. Broader analyses, such as Global Witness's 2021 report, implicated banks including ING in $44 billion of funding to major deforesters from 2013-2019, though ING-specific allocations were not itemized. In 2012, ING Bank N.V. agreed to forfeit $619 million to settle allegations by the U.S. Department of Justice and the Department's that it violated U.S. sanctions by processing over 14,000 transactions totaling approximately $1.7 billion between 2002 and 2007 involving entities in , , , , and , often using U.S. correspondent accounts and concealing the origin through deceptive practices such as omitting sanctioned country names or using shell companies. The settlement resolved civil and criminal investigations without admitting liability beyond the forfeiture, marking the largest penalty at the time for sanctions violations by a , and included enhanced compliance measures implemented by ING. In data privacy matters, ING's subsidiaries faced multiple regulatory penalties. In , ING Bank (Australia) Limited paid $53,280 in penalties in December 2022 to the Australian Competition and Consumer Commission for four alleged of Consumer Data Right rules, including failures to provide required data and notices to accredited data recipients between March and July 2022. Separately, in February 2005, a Belgian court ruled that ING Belgium had breached customer by monitoring employee communications without consent as part of an internal , ordering the bank to cease such practices and pay nominal , though no broader financial penalty was imposed beyond legal costs. More recently, in August 2025, Poland's data protection authority fined ING Bank Śląski 18.4 million zloty (approximately €4 million) for violations including inadequate measures and failure to report a promptly, determining the penalty proportionate to the bank's size and the infringement's severity. In tax-related disputes, an in 2024 upheld a decision against ING Bank SpA in a case, ruling that intra-group financing arrangements undervalued services provided to Italian branches, resulting in additional tax assessments and penalties for underreported from 2013 to 2015. ING has contested similar claims in ongoing proceedings, as noted in its regulatory filings, which disclose involvement in various governmental and legal actions across jurisdictions without specifying outcomes for all. These resolutions typically involved fines, enhancements, or procedural adjustments rather than admissions of systemic fault.

Strategic Developments

Sustainable Finance and ESG Initiatives

ING integrates sustainability into its core business strategy, emphasizing the financing of low-carbon transitions while managing (ESG) risks across operations and lending portfolios. As a signatory to the Finance Initiative (UNEP FI) Principles for Responsible Banking since 2019, ING commits to aligning its business model with the and , including targets for reducing financed emissions in high-impact sectors such as energy and power generation. The bank's ESG rating from remained at 'AA' as reconfirmed in August 2024, reflecting fifth consecutive year of stability in external assessments of its governance and risk management practices. In sustainable finance, ING's Wholesale Banking division operates a dedicated Sustainable Finance team that identifies and structures deals for clients pursuing green or transition projects, with a focus on renewable energy, green buildings, and sustainable infrastructure. The bank established its Global Green Funding Framework in 2015, updated in 2022 and 2024, to issue green bonds and other instruments financing eligible green assets aligned with International Capital Market Association (ICMA) Green Bond Principles and EU Taxonomy criteria, as verified by third-party reviewer ISS ESG. ING issued its inaugural green bond in November 2015, and by the first half of 2025, it had mobilized €67.8 billion in sustainable finance volumes across green loans, bonds, and sustainability-linked instruments, marking a 19% year-over-year increase from the prior period and its strongest half-year performance on record. Green loans specifically saw a 48% rise in transaction count and 17% volume growth in Q2 2025 compared to Q2 2024. ING's climate strategy, detailed in its September 2025 Climate Update, prioritizes sector-specific engagements to curb financed emissions, including phased reductions in exposure to upstream and gas financing and support for client decarbonization plans in line with 1.5°C pathways. Despite these efforts, activist groups have criticized ING for insufficient progress, filing a lawsuit in January 2024 through Milieudefensie—the behind the successful case—alleging the bank's financing activities contribute to excessive emissions and demanding accelerated cuts in portfolio-wide greenhouse gases, including scope 3 financed emissions. The case remains unresolved as of late 2025, highlighting tensions between reported mobilization volumes and ongoing exposures to carbon-intensive sectors, where empirical data shows sustainable financing still constitutes a minority of total lending.

Technological Advancements and Innovation

ING Group has invested significantly in to enhance and , including €800 million allocated under its for payments modernization and broader technological upgrades. This includes transitioning to a fully model, with standardized platforms and a borderless that simplifies systems and integrates to reduce manual processes. By 2025, ING's emphasized accelerating growth amid cost pressures, prioritizing cloud-first adoption to support scalable and data-driven services across its European operations. In , ING has deployed generative AI for customer-facing applications, launching a chatbot in collaboration with McKinsey's QuantumBlack to handle inquiries using advanced while prioritizing user-centric design. The bank integrates and advanced for operational improvements, with chief analytics officer Bahadir Yilmaz highlighting AI's role in predictive modeling and as of November 2024. By mid-2025, ING advanced agentic AI initiatives, enabling autonomous systems for tasks like application processing and personalized financial advice, aiming to streamline workflows and enhance without human intervention in routine areas. Blockchain technology features prominently in ING's wholesale banking innovations, particularly for trade finance digitization, where optical character recognition (OCR) and distributed ledger systems secure real-time transaction recording, minimizing errors and fraud. ING participated in the Utility Settlement Coin project to develop efficient blockchain-based payment mechanisms and, by 2025, initiated a MiCA-compliant stablecoin to facilitate compliant digital asset transactions in Europe. Complementary efforts include open banking integrations for seamless account management and payments, alongside spin-outs like Loan Optics to vc trade for digital loan platforms and Pyctor to GMEX Group for post-trade infrastructure. In September 2022, ING refocused its framework to align initiatives more closely with customer needs, establishing hubs for shared development and emphasizing generative alongside digitalization. These advancements support ING's broader goal of , with ongoing programs in accelerators and incubators fostering collaborations as detailed in its 2024 overview.

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