Case Study

Investigation Houston The ING Bank AML Compliance Failure Lan’s Enterprise Limited Training Program Training Objectives What you’ll learn today: Understand how a major international bank failed its AML obligations Identify systemic compliance failures and their root causes Recognize the consequences of prioritizing business over compliance Learn key red flags that were missed for years Apply lessons to prevent similar failures in your organization Case Overview ING Bank N.V. - The Facts Institution: ING Bank Nederland (ING NL) Period: 2010-2016 Investigation: “Operation Houston” by Dutch FIOD Settlement: €775 million (September 2018) Status: Only Dutch bank on Global Systemic Banks list What Is a Systemic Bank? Critical Infrastructure 9 million account holders in Netherlands 340 million payment transactions per month Essential to financial system functioning Higher responsibility for system integrity Trusted reputation in national/international trade With great power comes great responsibility ...

AML Training TSB Bank Breach Case Study Lan’s Enterprise Limited Training Program The Significance of This Case “Compliance is not optional - it’s a fundamental obligation.” First civil proceeding under AML/CFT Act $3.5 million civil penalty Precedent-setting case Impact on industry practices Why This Matters Regulatory Impact Sets enforcement precedent Defines compliance expectations Establishes penalty framework Business Implications Reputational damage Financial consequences Operational changes required Case Overview: TSB Bank Key Facts High Court of Wellington ruling Reserve Bank enforcement action Statement of claim: May 2021 Previous warnings ignored Critical Breaches Program Deficiencies ...