Our 2023 Annual Review is out! Last year, we received more than two million unusual transactions from over two thousand obliged entities. FIU-the Netherlands also declared 180,578 transactions suspicious last year. These
were shared with the investigative, intelligence, and security services through 17,848 case files. But, even more important than the figures, are the trends and phenomena that emerged from our analyses. We would like to
highlight three of them:
1️⃣ The Cash Compensation Model
A money-laundering method in which criminal cash is used to pay employees within labour-intensive sectors. Large, well-known companies in labour-intensive sectors such as construction and parcel delivery put out work
orders via (sub)contractors and pay them in via wire transfers. That job is then subcontracted several times with each successive link invoicing each other. The employees further down the chain who eventually carry out the
assignment are (partly) paid in cash. FIU-the Netherlands found several signals indicating that most of this cash came from the world for crime. The criminal who “offers” his cash to a subcontractor is compensated for this by
giro with the money from the initial client.
???? Part of the work our society runs on seems to be paid for with criminal cash with this CCM. This once again proves the intertwining of underworld and upper world in Dutch society.
???? In addition to money laundering, this phenomenon also brings risks of labour exploitation and creates very unfair
competition.
2️⃣ Organised healthcare fraud
A second aspect that emerged from analyses this year is indications of healthcare fraud. Developments started earlier, but insights were further strengthened in 2023. For instance, FIU-the Netherlands saw healthcare fraud in an organised context, which regularly involved complex networks of multiple legal entities and in some cases showed a link to intertwining with serious crime.
3️⃣ Sanction evasion
Tackling money laundering and terrorist financing explicitly requires an international focus. In 2023, we also regularly shared financial intelligence with foreign partners. A concrete example is the sharing of intelligence that contributed to countering shipments associated with sanctions evasion and dual-use goods. One analysis involved a situation where aircraft parts were exported via intermediary countries. An illustrative example of sanctions evasion, an important topic on which we had operational cooperation with several FIUs in 2023.
Read our full annual review on our website: https://lnkd.in/ektZPBYD
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