Financial Crime World

Financial Crime Threat Assessment of The Netherlands 2023-24

The Netherlands, a key player in international trade and a member of the European Union, is vulnerable to various financial crimes. This assessment highlights the country’s characteristics that make it susceptible to bribery, as well as the modus operandi employed by those involved in such activities.

Characteristics of The Netherlands

International Trade Hub

  • The Netherlands’ strategic location and large transport hubs make it a key entry point for international trade, increasing the risk of bribery.
  • Its role in international trade, including its position as a transit and destination country for goods, makes it vulnerable to bribery.

EU Membership

  • As an EU member, The Netherlands is subject to the EU’s anti-bribery legislation, which aims to prevent and combat corruption within the EU.

Strategic Geographic Location

  • The Netherlands’ geographic setting and sizeable transport hubs make it a key entry point for international trade, increasing the risk of bribery.

Modus Operandi

Bribery can take many forms, including:

  • Cash payments
  • Gifts
  • Travel expenses
  • Other inducements

Bribery is often facilitated by intermediaries, such as consultants or business associates, who may be unaware of the corrupt nature of their activities. In some cases, bribery may be concealed within legitimate business transactions or disguised as donations to charities.

Extent of the Threat in The Netherlands

According to the OECD’s Working Group on Bribery, The Netherlands has made progress in implementing anti-bribery measures, but further efforts are needed to effectively combat corruption.

  • In 2020, the Dutch authorities reported 234 cases of bribery, with an average value of €35,000 per case.

Sources

  • OECD Working Group on Bribery (2022) - Annual Report
  • The Netherlands Country Financial Crime Dashboard (2022) –Financial Crime News
  • The EU’s priorities for the fight against serious and organised crime for EMPACT 2022-2024 – Europol
  • Directive (EU) 2017/1371 of the European Parliament and of the Council of 5 July 2017 on combating fraud to the Union’s financial interests by means of criminal law, and repealing Council Act of 28 May 2008 and Council Directive 1999/ Gabriella 26 June 2003 (Official Journal of the European Union)
  • The Netherlands Country Financial Crime Dashboard (2022) –Financial Crime News
  • Expert input
  • OECD Working Group on Bribery (2022) - Annual Report
  • Dutch National Public Prosecution Service (2020) - Annual Report