Criminals are making extensive use of shell companies and straw owners to abuse the financial system – that is one of the worrying insights from our latest annual review. Our analyses reveal large-scale and organised abuse of legal entities. Seemingly legal business structures hide complex money laundering practices, tax fraud and even terrorist financing. This troubling development requires a broader, joint approach than criminal law alone.

Read the annual review 2024 here

Our analyses are based on reports of unusual transactions from reporting entities. In 2024, we received almost 3.5 million of these reports. This is a sharp increase compared to the previous year, when more than 2 million unusual transactions were reported. At the same time, the number of transactions declared suspicious declined from 180,578 in 2023 to 118,408 in 2024. These suspicious transactions were shared with the investigation, intelligence and security services in 16,306 files. Also in 2024, our analyses focused on a wide range of crimes. Examples include exploitation, sanctions evasion, terrorist financing, corruption, child pornography, drug trafficking, environmental crime and cybercrime. We registered a recurrence of several types of criminal behaviour, which we will explain below.

Misuse of legal entities
A significant proportion of our analyses concerns the systematic abuse of legal entities, such as private companies. For example, to conceal the identity of the actual owner or to purchase certain raw materials. We also identified networks of dozens – and sometimes even more – legal entities that appeared to have been set up purely to conceal money laundering. Malicious legal entities also feature prominently in our analyses of terrorist financing. We observed this trend across the entire spectrum that we monitor as FIU-the Netherlands.

Third-party payments
Another risk we discuss in more detail in the annual review is third-party payments. This type of payment concerns a supplier delivering goods or services to a customer, while a third party makes the payment. There are valid reasons for using this construction. For instance, when a customer is based in a country without a properly functioning banking system and still wants to pay for goods. However, it has become clear that third-party payments entail considerable risks. Especially, because the actual customer and/or the origin of the funds are not transparent. This enables criminals to conceal flows of money and commodities in complex structures.

Real estate
A third risk we repeatedly encountered in our analyses in 2024 relates to real estate. This concerns both the use of real estate to facilitate money laundering and the use of real estate to facilitate criminal processes. For example, housing victims of sexual exploitation.

Fraud
Finally, we continued our extensive analyses of various forms of fraud, including healthcare fraud. This revealed a picture of increasing complexity and intertwinement with serious crime.

Together, we see more
These risks and phenomena once again demonstrate the importance of cooperation within the Wwft domain to safeguard the integrity of the financial system. We are grateful for the reports from gatekeepers and the interventions by our public partners. Together, we see more.