Job Description

Compliance NL FCC

The purpose of Financial Crime Compliance (FCC) ING NL is to help ensure that ING NL complies with the Financial Economic Crime (FEC) Policy Framework within ING NL across Retail and Wholesale Banking. Within its 2LoD mandate, its goal is to detect and prevent financial economic crime from penetrating the financial system and thus assuring that the integrity of and trust in the financial system is maintained. As such it helps ensure that ING NL plays its role as gatekeeper according to the letter and spirit of the law and regulations, and as expected by Dutch society.

The FCC Advice & Control and Escalations function is part of ING’s Financial Crime Compliance (FCC) domain and is a key part of the second line of defense in the Netherlands. The function comprises three specialized teams:

• FCC NL Advice & Control– Provides expert guidance on Anti-Financial Crime requirements, supports the embedding of the FEC Policy Framework into local processes by the first line, and ensures timely and high-quality oversight of policy-related matters and Operational Effectiveness assessments.

• FCC Escalations WB NL – Handles complex KYC-related escalations for Wholesale Banking, providing risk-based decisions and advisory support to the first line, and contributes to integrated risk assessments in line with the FEC Policy Framework.

• FCC Escalations Retail NL – Performs similar responsibilities for Retail Banking, ensuring compliance and integrity through risk-based decisions and advisory support, while contributing to integrated risk assessments.

The Head of FCC Advice & Control and Escalations provides strategic direction and operational steering for the FCC NL Advice & Control and Escalations teams, ensuring effective coordination while respecting team leads’ operational responsibilities.

Acting as a trusted advisor and delegate MLRO for the Netherlands, the Head ensures high‑quality oversight of policy‑related matters and Operational Effectiveness, challenges the First Line of Defence, and ensures alignment with regulatory requirements and ING’s global FCC framework. The role includes delivering timely, risk‑based decisions on high‑impact escalations, translating regulatory expectations into clear guidance, and representing FCC NL in governance forums and towards regulators.

The function works closely with FCC NL Intelligence & Investigations, Group FCC, Legal, and first‑line partners to drive integrated risk assessments, strengthen oversight practices, and identify thematic insights that enhance the overall control environment. The position requires strong leadership, sound judgment, and the ability to distill complex regulatory and operational issues into clear, defensible recommendations. Equally important is the ability to influence senior stakeholders and ensure compliance considerations are prioritized without compromising regulatory integrity.

Tasks and Responsibilities

• Provide strategic direction for FCC NL Advice & Control and Escalations, ensuring strong second‑line governance aligned with ING’s global FCC framework.

• Act as Deputy Head FCC NL and delegate MLRO, including external representation towards regulators and industry bodies."

• Support and advise the Head of FCC/MLRO in setting and implementing the vision, strategy and direction for NL FCC, consistent with the vision and strategy for ING Group as set by Group FCC centrally.

• Ensure timely and high-quality oversight and monitoring of policy-related matters and Operational Effectiveness (OE), safeguarding compliance and alignment with ING’s global FCC framework.

• Oversee implementation of Anti-Financial Crime laws and regulations into local guidance and processes safeguarding compliance with Wwft, FATF, EU AML directives, and other regulatory requirements.

• Act as a trusted advisor to senior leadership and first line teams on Compliance implications of business decisions and change initiatives. This includes providing challenge, oversight and clear guidance on system and control requirements.

• Lead and oversee complex KYC‑related escalations for Retail and Wholesale Banking, ensuring timely, well‑reasoned, and risk‑based decisions. Enhance escalation governance and improve decision‑making quality across the domain.

• Drive integrated financial‑crime risk assessments across all segments, improving the identification, evaluation, and mitigation of AML, KYC, sanctions, ESR, and broader financial‑crime risks. Embed structured, risk‑based methodologies within second‑line oversight.

• Represent FCC NL in interactions with regulators, (internal) auditors, and industry bodies. Ensure high‑quality regulatory responses and maintain awareness of evolving standards, best practices, and expectations within the financial‑crime compliance landscape. Engage with regulators, industry bodies, and external stakeholders on governance and escalation matters.

• Provide direction, coaching, and oversight to team leads and specialized FCC teams. Foster a culture of integrity, continuous improvement, and accountability. Lead transformation initiatives and ensure teams are equipped to operate within an evolving regulatory environment.

• Improve the effectiveness and efficiency of FCC oversight processes. Promote data‑driven approaches—including analytics and AI/ML applications—to strengthen monitoring and decision‑making. Ensure continuous improvement of the Operational Effectiveness framework.

Competencies

Key Behavioural Competencies

• Leadership and Integrity – Demonstrates strong leadership presence, earns trust through expertise, and consistently upholds the highest ethical standards.

• Strategic Thinking and Problem-Solving – Anticipates regulatory and business developments, sees the broader context, and applies critical thinking to resolve complex challenges effectively.

• Influencing and Communication – Communicates with clarity and impact, adapting style to different audiences, and effectively influences stakeholders at all organizational levels.

• Proactive and Improvement-Oriented – Takes initiative, drives continuous improvement, and fosters innovation in governance, advisory, and escalation processes.

• Collaboration and Stakeholder Management – Builds strong, trust-based relationships across first and second lines, ensuring alignment between global and local priorities.

• Integrity and Accountability – Acts transparently and responsibly, safeguarding compliance and protecting the bank’s reputation.

• Change Leadership – Leads transformation initiatives, navigates evolving regulatory landscapes, and inspires teams to embrace and adapt to change.

• Analytical and Risk-Based Decision-Making – Makes timely, well-informed decisions on complex escalations using a structured, risk-based approach.

• Regulatory and Domain Expertise – Demonstrates deep knowledge of Anti-Financial Crime laws, regulations, and FCC domains (AML, CDD, Sanctions, etc.), applying expertise to guide sound decisions.

Technical Competencies

• Financial Crime Compliance Expertise: Deep knowledge of FCC domains including AML, CDD/KYC, Sanctions, Transaction Monitoring, Screening, Tax Integrity, ESR, and Non-Financial Risk, with the ability to interpret and apply global and local Anti-Financial Crime regulations in a second-line oversight context.

• Regulatory Knowledge: Strong understanding of relevant laws and regulations such as Wwft, FATF standards, EU AML directives, OFAC, and local sanctions regimes, with the ability to assess and oversee the practical implications of these requirements on local processes and controls.

• Governance and Oversight: Ability to design and maintain second-line governance frameworks, oversee the implementation of compliance requirements, and monitor adherence to policies and standards within FCC NL processes.

• (Integrated) Risk Management: Expertise in overseeing risk assessments across Retail and Wholesale Banking, ensuring identification, evaluation, and mitigation of financial crime risks through structured second-line processes.

• Escalation Handling and Decision-Making: Proficiency in managing complex KYC-related escalations and ensuring timely, risk-based decisions under pressure, balancing regulatory compliance with business needs.

• Operational Effectiveness and Efficiency: Knowledge of frameworks and methodologies to drive effectiveness in an efficient way, ensuring robust oversight of Operational Effectiveness assessments and continuous improvement initiatives.

• Data Analysis and Technology Awareness: Understanding of data-driven techniques for FCC, including analytics and AI/ML applications in KYC and transaction monitoring, and familiarity with FCC tooling and systems for screening, monitoring, and case management.

• Regulatory Engagement and Industry Standards: Ability to represent FCC NL towards regulators, auditors, and industry bodies, and maintaining awareness of best practices and emerging trends in financial crime compliance.

• Project and Change Management: Ability to steer large-scale change initiatives and projects within FCC NL, align stakeholders, and ensure effective implementation of new systems or processes.

Knowledge and Experience

• Relevant academic degree or equivalent professional qualification.

• Certification in AML / Sanctions (ACAMS or comparable).

• Extensive experience in Financial Crime Compliance, governance, and advisory roles within financial services.

• Minimum 15 years’ experience in risk management, including leadership roles in complex, multistakeholder environments.

• Excellent communication capabilities.

Reporting Line and Classification

The Head FCC NL III - Advice & Control and Escalations reports hierarchically to the Head of FCC NL / MLRO NL

This position is classified as: GJA 20 | Job Title: Head of FCC III | Job Family Group: Compliance