We are obliged to perform customer and transaction screening to detect potential and actual criminal activity. As a result, we pay particular attention to unusual transactions and to transactions that, by their nature, result in a relatively high risk of fraud, money laundering or terrorism financing. To do this we create and maintain a risk profile for you. If we suspect that a transaction is connected with money laundering or terrorist financing, we are obliged to report this to the authorities. Examples of factors that we take into account that may indicate an increased risk of fraud or money laundering and terrorist financing are: Changes in a person’s normal spending and payment behaviour, such as unexpectedly large amounts being transferred or debited. Payments to or from suspicious countries, stores or addresses. Two PIN payments by a single person in two vastly different locations at the same time. Being listed on an external referral register. This register is a list of the banks in the Netherlands that includes persons and institutions who have committed fraud or otherwise pose a risk to the financial sector. Financial institutions in the Netherlands can check whether persons and institutions are on the list and they can add them to the list. Being listed on any public national or international sanctions lists. To better tackle financial crime, banks have joined forces under the name Transaction Monitoring Netherlands (TMNL). TMNL helps ING to monitor payments transactions for signs that could potentially indicate money laundering and the financing of terrorism