ING Direct 2008 Annual Report Download - page 220

2.1 Consolidated annual accounts
The Charter and Framework and the supporting documentation were produced in close collaboration with the Business Lines, Legal and
Compliance Risk Management and business leaders.
– Updated FEC Policy and Guidance
The ING Group Financial Economic Crime (FEC) Policy provides a clear statement on Financial Economic Crime in order to guard against
any involvement in criminal activity, and to participate in international efforts to combat money laundering and the funding of terrorist
and criminal activities. The FEC Policy has been updated in 2008 explicitly recognising the differences between business lines and their
inherent FEC related risk, without lowering existing standards. A risk-based approach allows each Business Line to identify the criteria
to measure potential money laundering risks and implement proportionate measures and controls to mitigate these risks. Managing
Compliance Risk in accordance with the ING Group FEC Policy and Minimum Standards is required.
The FEC Minimum Standards are the basis for (local) procedures covering:
Customer Due Diligence and Know Your Customer;•
Anti-Money Laundering and Anti-Terrorist Financing.•
– Compliance Risk Management Training and Education
In 2008, Compliance Risk Management has developed and is executing several global training programmes, including:
1. ‘Managing Compliance Risk in your Business’. This programme targets the top four echelons of management (approximately 13,500)
worldwide during 2008/2009. Managers attending the training will not only gain a deeper understanding of the effective embedding
of ING’s three lines of defence model and the strategic value of Compliance Risk Management, but also learn practically what actions
they can take to strengthen the management of Compliance Risk as well as how to apply the Framework and tools.
2. ‘MLRO Master Class’. This new training programme targeted approximately 200 Money Laundering Reporting Officers. The course
aims to strengthen our MLROs’ understanding of the enhanced FEC and regulatory policy requirements.
3. ‘Compliance Officer Training’. This programme is designed for all Compliance Officers worldwide (approximately 750), across, and in
cooperation with, all Business Lines. The training programme has sections on technical knowledge, personal effectiveness and skills.
Additionally, the e-Learning course ‘Compliance, more than money’ created in 2006 and made mandatory by the Netherlands Board for
all ING employees in the Netherlands was refreshed. The follow-up course named ‘Compliance, part of our business’ takes into account
changes in financial services laws and regulation and internal ING policies and procedures.
– Enhanced Business Aligned Communications
To ensure continued awareness of the importance of effectively managing Compliance Risk a campaign entitled ‘Play to Win, Know
the Rules’ was launched. The key message of the campaign is that managing Compliance Risk is an integral part of managing business
and must be embedded into daily practice and business strategy. The campaign helps further drive understanding and behaviours
relating to the management of Compliance Risk. It includes a one-pager with key messages for business teams, as well as a PowerPoint
presentation and short videos by each Executive Board member stating why they believe managing Compliance Risk is integral to building
sustainable businesses.
The four key messages defining good Compliance Risk Management are:
knowing, understanding and applying the rules;•
a culture where people are trusted and accountable;•
effectively managing Compliance Risk in our businesses; and•
vital for sustainable profitable growth – our licence to operate.•
Discussions with regulators and implementation of enhanced compliance and risk management procedures
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
Risk management (continued)
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