Why Did ING Bank Refuse To Transfer Funds Connected To Cuba? There Were 619 Million Reasons.
/Prensa Latina News Agency
Havana, Republic of Cuba
19 January 2022
London, Jan 19 (Prensa Latina) The ING Dutch bank [Amsterdam, The Netherlands-based ING Groep N.V.; 2021 assets US$1.1 Trillion] blocked donations to a Progressive International delegation that will travel to Havana to support free access to Covid-19 vaccines promoted by Cuban, it was reported here today.
By: Ana Luisa Brown
In a communique sent to Prensa Latina on Wednesday, the organization that groups left-wing activists from all over the world denounced that the multinational banking institution based in the Netherlands has joined the economic, financial and commercial blockade maintained by the United States against the Caribbean island for 60 years. The text adds that the decision taken by ING shows the extraterritorial scope of the unilateral measure imposed by Washington, which seeks, it said, not only to asphyxiate Cuban, but also to hinder international solidarity with that country. After branding the decision of the Dutch bank as scandalous, the organization recalled that while European countries administer booster doses, the majority of the inhabitants of the poorest nations on the planet have not even received an injection against the SARS-CoV-2 coronavirus. In the face of this vaccine blockade, Cuba emerges as a driving force of internationalism with its promise to share its vaccines with the world, he added. Progressive International launched weeks ago a fundraising campaign to finance the trip to Havana of a delegation that will organize a special briefing on the Caribbean island’s efforts to produce its own anti-Covid-19 vaccines, and its willingness to share them with the world. Despite the blocking of donations by ING Bank, a spokesperson for the organization told Prensa Latina that plans to hold the meeting in the Cuban capital remain unchanged. The event scheduled for January 25, which is part of the Union for Vaccine Internationalism promoted by Progressive International, will be attended by Cuban scientists, ministers and public health officials. pgh/abo/mem/nm
Correspondence From ING To Progressive International
Onderwerp
Betalingsopdracht Leeuwarden, 18 januari 2022
Geachte heerKenmerk
Wij hebben uw opdracht ontvangen om van uw Betaalrekening met over te maken naar Progressive International (Services) Ltd in Duitsland onder vermelding van: In verband met ons beleid om geen zaken te doen of te faciliteren met een aantal nader omschreven landen en gesanctioneerde partijen, kunnen we deze transactie niet uitvoeren. In deze brief leest u meer hierover.
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ING evalueert periodiek haar dienstverlening vanuit econornisch, strategisch en risico-perspectief. Mede op basis van deze evaluatie is het beleid gebaseerd. Dit brengt met zich mee <lat ING om zakelijke redenen geen klantrelaties wenst aan te gaan of te continueren en ook geen transacties wenst te faciliteren met directe of indirecte betrokkenheid van bepaalde landen, personen of bedrijven.
Deze beslissing is van invloed op:
de landen: Cuba, Iran, Noord-Korea, Sudan, Syrie en de Krirn regio in Oekrai:ne;
door de overheid gecontroleerde banken en bedrijven uit Wit-Rusland;
overige (inter)nationaal gesanctioneerde personen/entiteiten.
Om bovengenoemde redenen kunnen wij de opdracht niet uitvoeren.
Het transactiebedrag wordt zo spoedig mogelijk, inclusief de eventueel in rekening gebrachte kosten, naar uw Betaalrekening teruggeboekt.
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Met vriendelijke groet, KYC Specials
Google Translate (with redactions from original document)
ING
Tesselschadestraat 1, 8913 HA Leeuwarden
Postbus 99960, 8900 GA Leeuwarden
ING Bank N.V. statutair gevestigd te Amsterdam Handelsregister nr. 33031431 Amsterdam
Subject Payment order Leeuwarden, January 18, 2022
Dear Sir: We have been instructed to transfer from your Payment Account to Progressive International (Services) Ltd in Germany stating:
In connection with our policy of not doing or facilitating business with some specified countries and sanctioned parties, we do not execute this transaction. You can read more about this in this letter.
Our Policy
ING periodically evaluates its services from an economic, strategic and risk perspective. The policy is based partly on this evaluation. This implies that ING does not wish to enter into or continue customer relationships for business reasons, nor does it wish to facilitate transactions with direct or indirect involvement of certain countries, persons or companies.
This decision affects: - the countries: Cuba, Iran, North Korea, Sudan, Syria and the Krirn region in Ukraine; - government-controlled banks and companies from Belarus; - other (inter)nationally sanctioned persons/entities. For the above reasons, we cannot carry out the order. The transaction amount will be refunded to your Payment Account as soon as possible, including any costs charged.
We will send this letter both by post and by e-mail to
More information
Do you have any questions regarding this letter? Then you can reach us on working days from 08.30 to 17.00 on telephone number 058 295 2854.
ING Bank N.V.
Amsterdam, The Netherlands
October 2020
Link: ING Financial Economic Crime Statement- October 2020
United States Department of the Treasury
Washington DC
12 June 2012
U.S. Treasury Department Announces $619 Million Settlement with ING Bank, N.V.
Largest-Ever Settlement Reached in a Sanctions Case
Link: https://www.treasury.gov/press-center/press-releases/pages/tg1612.aspx
Miami Herald
Miami, Florida
1 April 2021
Excerpts:
The shift also corresponded with a U.S. investigation into the Dutch bank ING, which had a 50% stake in a bank in Curacao called Netherlands Caribbean Bank, or NCB. The bank was incorporated as a joint venture in 1993, and Acemex was one of two Cuban partners in it.
In July 2006, OFAC designated the Curacao-based bank to the Specially Designated Nationals list, another one of the mechanisms of U.S. blacklisting, because of its substantial Cuban ownership. It did not blacklist Acemex. The Caribbean bank was shut down, but ING ultimately acknowledged in 2012 that it moved more than $2 billion through the United States on behalf of Cuba and Iran — some of it through Netherlands Caribbean Bank. In a Treasury Department settlement ING agreed to forfeit $619 million.
This screenshot shows part of a confidential State Department memo sent from The Hague in December 2007 discussing an investigation into the Dutch bank ING and its operations in and with Cuba. The document lists Acemex Management Company Limited, by then domiciled in tiny Liechtenstein, as co-owner of a bank in the former Dutch colony of Curaçao.
The Wall Street Journal
New York, New York
12 June 2012
ING Fined a Record Amount
Penalty of $619 Million Tied to Cuba, Iran for Violating U.S. Economic Sanctions
By Reed Albergotti
ING Bank has agreed to pay a record penalty of $619 million for illegally moving billions of dollars through the U.S. banking system on behalf of Cuban and Iranian clients and threatening to fire employees if they failed to conceal the origin of the money.
The U.S. prohibits certain countries and entities from accessing the U.S. banking system through sanctions enforced by the Treasury Department's Office of Foreign Assets Control. Banks in Manhattan, which process most of the world's U.S. dollar payments, use "filters" to prevent terrorists, money launderers and other criminals from gaining access.
But the bank, a unit of ING Groep NV, one of the Netherlands largest banks, used a system to "strip," or delete, references to Cuba and Iran and, through more than 20,000 separate transactions, successfully moved more than $2 billion through the U.S. financial system. It is the fourth major bank to settle with New York and U.S. authorities in recent years over such activities.
In 2009, Switzerland's Credit Suisse Group AG agreed to pay $536 million and the U.K.'s Lloyds Banking Group PLC agreed to pay $350 million to settle similar allegations with New York and U.S. authorities. The U.K.'s Barclays PLC settled allegations in 2010, agreeing to pay $298 million. ING's fine is the largest ever for these types of violations.
ING profited by courting business from sanctioned entities like Iran and Cuba, according to court documents filed on Tuesday. Its clients in Cuba included a range of people, from individuals who wanted to cash U.S. travelers checks to government ministries. It also engaged in transactions with Iran's central bank and state-owned National Iranian Oil Co.
Cyrus Vance Jr., the Manhattan district attorney, who is investigating other banks for possible similar violations, said in an interview Tuesday that "stripping" cases are about more than monetary damages. "They ensure that rogue regimes and human-rights abusers are isolated and feel economic pressure from sanctions," he said.
Mr. Vance and the Justice Department noted that ING devoted significant resources to conducting an internal probe starting in 2006 and cooperating with the government. U.S. authorities said they would drop charges against the bank after 18 months, provided ING agrees to certain overhauls and cooperates with the government.
From the early 1990s until 2007, employees processed these transactions with the approval and encouragement of senior corporate managers and legal and compliance departments, the court documents said.
On several occasions, ING employees raised concerns about the practice, but were rebuffed by executives in ING's compliance department, the documents said. In 2003, an employee in London in an email implied that the "stripping" records might be problematic and pointed to a global "climate of anti-money-laundering and [Office of Foreign Assets Control] sanctions," the documents said. The concerns were rebuffed, according to court documents.
In 2004, after receiving an email from another person in ING's London offices, inquiring about the bank's practice of covering up its dealings with Iran and Cuba, a legal department employee responded: "We have been dealing with Cuba (and ways around clearing through Manhattan) for a lot of years now and I'm pretty sure that we know what we are doing in avoiding any fines," according to court documents. The court documents didn't name the employees involved in the email exchanges.
The Dutch bank on Tuesday acknowledged responsibility for its conduct and that of its employees as part of the deferred prosecution agreement with the Manhattan district attorney's office and the Justice Department. At least three separate investigations into ING were under way by U.S. and New York authorities for the past two years.
Jan Hommen, CEO of ING Groep, said in a statement: "The violations that took place until 2007 are serious and unacceptable. The facts as compiled in the statement of the Department of Justice describe a very different ING than the company we're all working so hard for today."
To get around Cuban sanctions, ING often worked with a subsidiary, the Netherlands Caribbean Bank, a joint venture with a shipping company owned by the Cuban government, according to the court documents. ING's branch in Curaçao accepted American currency from the Cuban subsidiary and then "stripped" it of any connection to the communist nation so the money could flow through U.S. financial institutions.
In emails excerpted in the court documents, ING executives talked of firing employees who failed to strip out records of the bank's dealings with sanctioned entities and at one point actually posted a how-to guide to the practice of stripping on a company intranet. In one email, an attorney in ING Groep's legal department described the widespread practice of stripping within the company as ING's "little white lie."
The system by which ING circumvented U.S. sanctions also involved forming shell companies and rerouting payments through multiple banks so they couldn't be traced back to their origins in Cuba and Iran. According to court documents, this practice was called "handighei," which roughly translates as "tricky business."
ING said it took a provision of €370 million ($462 million) in the first quarter of the year to cover the penalties, set up a team to prevent and detect money laundering, closed its representative office in Cuba in 2007, and ended relationships with sanctioned entities.
