ING Direct 2009 Annual Report Download - page 240

2. Advisory
Compliance Officers proactively advise their CEO, Management, local boards and committees, the next higher level Compliance Officer,
and employees on Compliance Risk, responsibilities, obligations and concerns.
The Compliance Risk Management function participates in the Operational Risk Management Scorecard process which measures how the
risk management framework including Compliance Risk Management is embedded in each business. Scoring is based on the ability of the
business unit to demonstrate that the required policies and procedures are implemented.
3. Scorecard
The Compliance Risk Management function works with the Operational Risk Management Scorecard process to evaluate how well
the Compliance Risk Management Framework is embedded in each business. Scoring is based on the ability of the business unit to
demonstrate that the required policies and procedures are implemented. The scoring indicates the level of control within the business
units and the result is integrated with the Operational Risk Management results into ING’s Dutch Central Bank approved regulatory
capital model (AMA).
Extra-Territorial regulations
As a result of our frequent evaluation of all businesses from economic, strategic and risk perspectives ING continues to believe that for
business reasons doing business involving certain specified countries should be discontinued, which includes that ING has a policy not to
enter into new relationships with clients from these countries and processes remain in place to discontinue existing relationships involving
these countries. At present these countries include Myanmar, North Korea, Sudan, Syria, Iran and Cuba. ING Bank N.V. has in 2009
liquidated the Netherlands Caribbean Bank, which had been a 100% owned subsidiary since 2007.
ING Bank N.V. has continued discussions with its Dutch bank regulator De Nederlandsche Bank (DNB) related to transactions involving
persons in countries subject to sanctions by the EU, the US and other authorities and its earlier review of transactions involving sanctioned
parties. In connection with that review and related discussions ING Bank has undertaken to complete the global implementation of
enhanced compliance and risk management procedures, and to monitor the implementation of such procedures on an ongoing basis,
as instructed by DNB. ING Bank also remains in discussions with authorities in the US and in other jurisdictions concerning these matters,
including with respect to ongoing information requests and it is not possible to predict at this time the outcome thereof. Financial
institutions continue to experience close scrutiny by regulatory authorities, governmental bodies, shareholders, rating agencies, customers
and others to ensure they comply with the relevant laws, regulations, standards and expectations. Bank and insurance regulators and
other supervisory authorities in Europe, the US and elsewhere continue to oversee the activities of financial institutions to ensure that
they operate with integrity and conduct business in an efficient, orderly and transparent manner. ING seeks to meet the standards and
expectations of regulatory authorities and other interested parties through a number of initiatives and activities, including scrutinizing
account holder information, payment processing and other transactions to support compliance with regulations governing money-
laundering, economic and trade sanctions, bribery and other corrupt practices. The failure or perceived failure by ING to meet applicable
standards in these areas could result in, among other things, suspension or revocation of ING’s licenses, cease and desist orders, fines, civil
or criminal penalties and other disciplinary action which could materially damage ING’s reputation and financial condition, and accordingly
ING’s primary focus is to support good business practice through its Business Principles and group policies.
Main developments in 2009
Building Customer Trust
Group Compliance Risk Management and Corporate Operational Risk Management have worked closely together with the business lines
to strengthen ING’s Product Approval and Review Process. This work demonstrates ING’s commitment to treating customers fairly and
ensuring alignment with the various regulatory initiatives including the Dutch Banking Code, new FSA regulations in the UK and US
President Obama’s white paper on financial regulatory reform.
Regulator relationships
Group Compliance Risk Management continued to invest in pro-active relationships with regulators in the jurisdictions where ING
operates, striving for an open approach and cooperation in identifying and mitigating compliance risks for ING.
Further embedding of Financial Economic Crime & Extra-Territorial Laws
ING’s commitment to prevent any involvement in criminal activity was reinforced by the review and updating of the Financial Economic
Crime and Extra Territorial policies.
In keeping with our obligation to provide consistent relevant education a series of specialised face-to-face training sessions were held for
over 250 Money Laundering Reporting Officers. These global events not only provided information on the updated policies but also gave
a valuable opportunity to share best practices.
ING Group – Non-financial risks
Risk management (continued)
2.1 Consolidated annual accounts
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