Citing EU sanctions, ING capped accounts it recorded as Russian at EUR 100,000. Four customers, all Dutch nationals, complained; the Dutch equality body found no prohibited distinction.
On 12 April 2022 ING Bank N.V. emailed customers whose records at the bank showed Russian nationality. Because of EU sanctions, the email said, restrictions would apply to their accounts: a maximum total balance of EUR 100,000 or EUR 100,000 in total credits, active monitoring of international payments, and a marker in ING's administration that could slow applications for new or additional products and services.
Four customers complained to the Netherlands Institute for Human Rights (College voor de Rechten van de Mens). Each held Dutch nationality at the time. One was a man born in Uzbekistan who had held Dutch nationality since 1999. One was a woman holding both Russian and Dutch nationality. One was a woman who acquired Dutch nationality in 2020, renounced Russian nationality in 2021 and held only Dutch nationality from 1 February 2022. The fourth was a man who acquired Dutch nationality after opening the account and told the hearing that he had never informed ING of it.
The College heard the four cases together on 25 October 2022 and decided them on 6 December 2022 as opinions 2022-141, 2022-142, 2022-143 and 2022-144.
In 2022-142, 2022-143 and 2022-144 the College held that ING had made a direct distinction on grounds of nationality. Under the Dutch Equal Treatment Act (AWGB), however, such a distinction is not prohibited where it rests on generally binding rules ('algemeen verbindende voorschriften'), which the College identified as EU Regulation 2022/328.
In 2022-141, the case of the man born in Uzbekistan, the College held that ING had made no distinction on grounds of nationality at all. ING had registered him as Russian in error and had failed to update its systems with the Dutch identity document added to his file in 2006. It had lifted the measures and apologized before it was informed of the discrimination complaint. He stated at the hearing that he had suffered no disadvantage.
Each of the four opinions concluded: 'ING Bank N.V. heeft jegens [. . . .] geen verboden onderscheid op grond van nationaliteit gemaakt.' The record for this entry is the four published opinions of the College voor de Rechten van de Mens, at https://oordelen.mensenrechten.nl/oordeel/2022-142 and the adjacent opinion numbers.
Sources
Where it stands
All four complaints failed. In each case the College found that ING had not made a prohibited distinction on grounds of nationality. Its oordelen are non-binding opinions rather than court judgments and are not subject to appeal. No later court decision, correction or withdrawal is recorded on the four published pages.