For new customers, and in accordance with regulatory obligations, ING Luxembourg is obliged to collect from the customer a signed tax self-certification including their tax residence and their Tax Identification Number. The customer is required to confirm and prove their American status (U.S. Person or non-U.S. Person). Otherwise, ING is not authorised to open a bank account.
ING Luxembourg will continue to offer all its services to US citizens in connection with current and savings accounts, provided that these citizens agree to provide the information required by FATCA.
It should be noted that ING Luxembourg cannot provide securities services to US customers and that if a customer initially identified as non-US becomes US (by citizenship or residence), any securities services provided would have to be stopped and the financial assets would have to be sold or transferred to another financial institution.
If the required documents are not provided within a very specific timeframe, ING Luxembourg will have to consider the customers concerned as undocumented accounts. ING Luxembourg will then be obliged to restrict or even close these accounts and to communicate them to the IRS (via the Luxembourg tax authorities).