According to the Dutch newspaper “Het Financieel Dagblad” the US Department of Justice has started a penal procedure against ING for alleged transactions with Cuba, Iran and Syria, which are forbidden by US Law. Fines could be as high as a few hundred million euro. No more details available, but ING claims that it didn't do anything wrong. The investigation started in 2006 when INGwas conducting business with Cuba, Iran and Syria. Activities were downsized significantly by ING following US restrictions/prohibition to conduct business with those countries. Our View: It is difficult to gauge at this stage whether ING can be held liable. ABN Amro had a similar investigation in 2005 which ended up with a payment of an $ 80m fine and $ 500m court settlement. Conclusion: We remain Accumulating with unchanged target at € 9.0.