ING Bank N.V. · Governance finding · severity 3 of 5
On 25 July 2024 the Netherlands Institute for Human Rights (College voor de Rechten van de Mens) found that ING Bank indirectly discriminated on the ground of race when its automated sanctions screening repeatedly blocked and questioned two customers' payments because a relative's non-Dutch-sounding name partially matched names on European sanctions lists. Per the Institute, an algorithm scans transactions and a bank employee then decides whether to block one; the system was not described as AI. The Institute also found ING handled one customer's complaint carelessly. Its opinions (2024-62 and 2024-63) are non-binding and carry no fine. ING said it took the decision very seriously and had apologised for its communication; in May 2025 the CEO of ING Netherlands apologised to customers for unnecessary questions in money-laundering and terrorism-financing checks.
Record last reviewed Oct 21, 2026 · Markdown
Date
Institution
Country
Netherlands
AI system
Automated sanctions-list screening of payment transactions that flags partial name matches for staff review; not described as AI
AI?
Automated system not described as AI
The system was automated, but neither the institution nor a regulator described it as AI; it is listed because it is routinely discussed as an AI failure.
Category
Status
Regulator finding
Severity
3 of 5
Impact
Two complainants had payments repeatedly blocked and were asked for relatives' personal details; the Institute said the consequences of transaction screening are serious for individual customers and for society. · No fine, compensation or loss figure applies: the Institute's opinions are non-binding. ING has not published how many customers its name screening flags.
What happened?
Dutch banks must screen customers and payments under the anti-money-laundering act (Wwft) and the Sanctions Act. According to the Institute, ING searches for parts of names that appear on sanctions lists, allowing for typing errors, so a name does not have to match exactly. In its words, "Een algoritme scant transacties op mogelijke verdachte kenmerken. Een bankmedewerker moet vervolgens mogelijk verdachte transacties beoordelen en bepalen of een transactie geblokkeerd wordt" ("An algorithm scans transactions for possibly suspicious characteristics. A bank employee must then assess possibly suspicious transactions and decide whether a transaction is blocked"; our translation). The record does not describe the matching system as AI or machine learning.[1]
In the first case, a customer transferred €100 from his own account at another bank to his ING account in September 2022 and mentioned his brother's Arabic-sounding name in the description. ING blocked the transfer, asked for the brother's full name, address and date of birth, did not answer the customer's questions, and blocked a later transfer for the same reason. In the second case, ING blocked several payments from 2021 onwards by a woman whose husband has a non-Dutch-sounding surname, asking each time for the same details about him; ING acknowledged before the Institute that it had wrongly asked for the same information more than once.[2][3]
The Institute accepted that sanctions screening serves a legitimate aim, but found that because the sanctions lists mostly contain non-Dutch-sounding names, the method blocks and checks people of non-Dutch origin more often, which is indirect discrimination. It concluded: "Het College oordeelt dat de transactiescreening de belangen van personen met niet-Nederlandse afkomst onevenredig schaadt en dat er sprake is indirecte discriminatie" ("The Institute finds that the transaction screening disproportionately harms the interests of persons of non-Dutch origin and that there is indirect discrimination"; our translation). It said ING's communication, "in which no personal explanation or clarification was given at all", played an important role.[1][3]
The complaints were brought with the support of the Public Interest Litigation Project (PILP) and Discriminatie.nl. According to PILP, ING argued that one flagged first name was too similar to an alias of a former secretary of Saddam Hussein; PILP said the ruling should apply to every Dutch financial institution using similar screening. A third complaint against ING was still pending when the two opinions were published.[4][5]
When did it happen?
- Sep 2022
ING blocks a customer's €100 transfer because his brother's Arabic-sounding name in the description partially matches a sanctions-list name.[3]
- Feb 28, 2024
The second complainant files her request for an opinion with the Netherlands Institute for Human Rights.[2]
- Jun 13, 2024
The Institute hears the second complainant's case.[2]
- Jul 25, 2024
The Institute publishes opinions 2024-62 and 2024-63 finding that ING indirectly discriminated on the ground of race; a third case is still pending.[1][4]
- May 2025
Peter Jacobs, CEO of ING Netherlands, apologises in an open letter to customers for unnecessary questions and unclear explanations in anti-money-laundering and counter-terrorism checks.[6][7]
What was the impact?
- Customers: Two complainants had payments repeatedly blocked and were asked for relatives' personal details; the Institute said the consequences of transaction screening are serious for individual customers and for society.[1][3]
- Other: No fine, compensation or loss figure applies: the Institute's opinions are non-binding. ING has not published how many customers its name screening flags.[1][3]
Severity 3 of 5: A regulatory-type finding: the Netherlands Institute for Human Rights found prohibited indirect race discrimination against two customers and careless complaint handling; the opinions are non-binding, no fine was imposed and no loss figure has been published.
How did ING Bank N.V. respond?
Before the Institute, ING said it must enforce national, European and international sanctions and could not do so other than with its current screening method, because supervisors penalise it heavily for letting even one payment through incorrectly; the Institute recorded that ING had apologised and acknowledged its communication around transaction screening must be more careful. After the ruling a spokesman said the bank would take the decision very seriously and "will improve the experiences of our clients in client investigations, for instance by explaining more clearly why we are asking questions". In May 2025 ING Netherlands' CEO wrote: "I sincerely apologize for: Asking unnecessary questions when we already had the information".[1][3][5][6]
What was the outcome, and did regulators act?
The Institute found prohibited discrimination in both cases and careless complaint handling in one; its opinions are non-binding and no sanction followed. ING said in May 2025 that it was asking fewer questions, explaining them better, working with civil-society organisations and religious institutions, and calling customers who report discrimination. As of 2026-10-21 we found no published opinion in the third pending case.[1][6][7]
Was ING's payment screening an AI system?
No source calls it AI. The Netherlands Institute for Human Rights describes an algorithm that scans transactions for partial matches with names on European sanctions lists, allowing for typing errors, after which a bank employee decides whether to block the payment and question the customer. We classify it as automation, not AI.
Was ING fined for discrimination?
No. The Institute's opinions 2024-62 and 2024-63 found prohibited indirect discrimination on the ground of race and careless complaint handling, but its opinions are non-binding and carry no fine or compensation. The complainants' supporters said the finding should change screening practice at every Dutch financial institution.
Why did the Institute find discrimination if sanctions screening is a legal duty?
It accepted that screening against sanctions lists serves a legitimate aim. But because those lists mostly contain non-Dutch-sounding names, partial-name matching blocks people of non-Dutch origin more often, and ING had not shown it gave enough weight to wrongly affected customers, partly because it gave them no personal explanation at all.
What did ING change after the ruling?
A spokesman said in July 2024 that ING would explain more clearly why it asks questions. In a May 2025 open letter the CEO of ING Netherlands apologised for unnecessary questions and an impersonal tone, and listed steps: fewer questions, better explanations, a team for religious institutions, and direct calls to customers who report discrimination.
- ING discrimineert twee klanten door betalingen te blokkeren en controleren vanwege niet-Nederlands klinkende naam official
- Oordeel 2024-62: ING discrimineert een vrouw op grond van ras, door haar betalingen herhaaldelijk te blokkeren en controleren official
- Decision 2024-63: ING discriminated against a man on the ground of race, by blocking and checking his payment official
- Verdict: ING discriminates against customers based on their ethnicity in transaction checks news
- ING carried out extra checks on clients with foreign names news
- Open letter to customers on discrimination (May 2025) official
- ING apologises for discriminatory impact of anti-fraud checks news
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