ING’s Sanctions Compliance

At a glance

Our approach to sanctions compliance is grounded in ING’s commitment to doing the right thing and protecting the integrity of the financial system. We recognise that breaches of applicable Australian or international sanctions laws or obligations can create significant risks for ING, our customers, our employees, and the communities in which we operate.

How does ING comply with sanctions laws/obligations?

Clear and consistent standards

We maintain clear standards that set out the activities ING does not engage in, including any direct or indirect dealings involving:

• • Individuals or entities subject to sanctions, or those acting on their behalf
• • Sanctioned goods, services, sectors or activities
• • Transactions connected to sanctioned countries or regions

Ongoing risk assessment

We regularly assess our exposure to sanctions risk and review our processes to ensure they remain appropriate as laws and geopolitical conditions evolve.

Customer and third party due diligence

We undertake due diligence on customers, their beneficial owners and relevant third parties to help ensure we do not facilitate prohibited activities.

Screening and monitoring

We screen customers, accounts and payment activity against relevant sanctions lists and monitor transactions to identify activity that may require review or action.

Staff training and awareness

Our employees receive regular training to understand sanctions obligations and to recognise when escalation or additional review is required.

Actions ING may take to comply with sanctions laws

To meet Australian and international sanctions laws and obligations, ING may apply restrictions to accounts, transactions or relationships where required by law. This may include:

• • Restricting, stopping, rejecting or declining certain transactions
• • Limiting access to services such as mobile or internet banking
• • Restricting, suspending or closing accounts
• • Deciding not to enter into, or continue, certain customer relationships or activities

Sanctioned Countries and Regions

Suspension or termination of Interactive Services

In addition to other account restrictions which may apply under the product terms and conditions, we may suspend or terminate access to Interactive Services, including Online Banking or Mobile Banking, if you are travelling to or residing in a sanctioned jurisdiction listed below:

• • Cuba
• • Iran
• • North Korea
• • Sudan
• • Syria
• • Crimea

Customers in sanctioned countries or regions

Customers who are located in, reside in, or have a connection to sanctioned countries or regions may be subject to restrictions which can affect access to accounts, services, or transactions. These restrictions may be applied without prior notice, subject to the applicable product terms and conditions and our legal obligations.

Adapting to change

Sanctions requirements can change quickly. We update our processes on an ongoing basis to ensure compliance with our legal and regulatory obligations. The list of sanctioned countries and regions may change at any time in response to global developments, regulatory requirements, or emerging risk indicators.

Need help?

If you have questions about how these restrictions may affect your transactions or accounts, please contact us.