The 2024 Annual Review by the Netherlands’ Financial Intelligence Unit (FIU) outlines major progress in the country’s ongoing fight against money laundering, predicate offenses, and terrorist financing.
A key trend highlighted in the report is the significant rise in reports of unusual transactions (UTs), even as the number of suspicious transaction reports (STRs) declined. This shift was largely due to evolving reporting practices and increased compliance among newer sectors.
In 2024, the FIU received close to 3.5 million UT reports, up from 2.3 million the previous year. Most of this growth came from three sectors: payment service providers (PSPs), cryptocurrency exchanges, and non-bank credit card issuers. PSPs alone generated over 1.4 million reports, more than 40% of the total, despite 70% of those having no direct connection to the Netherlands, highlighting the country’s role as a global financial transit hub.
Crypto exchanges submitted 578,312 UTs, over twice the number in 2023, reflecting higher transaction volumes and asset values. These reports mainly used objective indicators like transaction thresholds. The sector showed greater regulatory engagement, with more firms establishing compliance departments to meet obligations under the Wwft (Dutch anti-money laundering law).
Conversely, traditional banks reported fewer UTs. A key reason was one major bank’s move from submitting individual to aggregated reports, correcting previously skewed data. Despite the decline, banks remained among the top three reporting sectors.
The Dutch Central Bank (DNB) contributed to reporting shifts by requiring retrospective submission of all fraud-related transactions, particularly from credit card firms—leading to a surge in filings. Meanwhile, STRs dropped from 180,578 in 2023 to 118,408 in 2024, though their combined financial value reached €17.5 billion, including 15 cases over €100 million. Notably, 86% of STRs were based on subjective assessments, highlighting the continued importance of expert judgment in identifying suspicious behavior.
The review also warned of persistent risks associated with legal entity misuse, such as shell companies, straw ownership, and the Cash Compensation Model, tactics used for laundering money, evading taxes, and supporting organized crime. These practices often involved professionals who were either complicit or willfully ignorant. The FIU stressed that tackling this issue requires coordinated, cross-sector reforms, not just individual prosecutions.
Another growing concern was third-party payments, where individuals not involved in a transaction provide funding. These setups were increasingly linked to money laundering and sanctions evasion, and widely used by organized crime networks to conceal illegal cash flows and support terrorism financing.
Real estate continued to be a common vehicle for laundering illicit funds. The FIU found extensive evidence of criminals using complex ownership structures involving shell firms and straw buyers, often internationally, to convert cash into legitimate rental income. Some properties were also used for criminal operations, including drug labs, illegal gambling, and sexual exploitation.
Fraud remained prevalent, both in public-sector schemes and peer-to-peer scams. Healthcare and benefits fraud were especially common, often executed through fake employment or care agencies, with ties to tax evasion and off-the-books wage payments. These schemes unfairly undermined compliant businesses and strained public resources.
Corruption investigations also uncovered bribery schemes involving Dutch corporations and civil servants, often channeled through intermediaries, shell entities, or family-linked companies. Such cases were referred to anti-corruption authorities.
Furthermore, the FIU disrupted networks related to child exploitation and abuse, some with financial enablers, through targeted collaboration and knowledge sharing.
Cases related to terrorist financing rose from 247 in 2023 to 309 in 2024. These often involved extremist religious or political groups, with financial trails pointing to weapons purchases and broader funding networks. Again, underground banking and third-party payments were linked to this form of financing, described as Crime Enabled Terrorism Financing (CETF).
A significant regulatory milestone came with the EU’s adoption of a new anti-money laundering package on 30 May 2024. The package includes the Anti-Money Laundering Regulation (AMLR), the sixth directive (AMLD6), and the creation of a centralized AML Authority (AMLA) based in Frankfurt. Set to take effect in July 2027, this framework enforces standardized compliance across the EU, encourages joint analysis, and enhances coordination among FIUs.
To improve data quality, the FIU introduced tailored reporting forms and sector-specific guidelines. Local partnerships also yielded strong results—for example, joint efforts in Rotterdam and Amsterdam led to the seizure of weapons, drugs, and the exposure of large-scale mortgage fraud schemes involving hundreds of properties.
