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Dutch Efforts to Combat Financial Crimes Show Progress, but Improvement Needed
The Netherlands has made significant strides in combating money laundering and terrorist financing, with its measures delivering good results. However, the country must do more to prevent legal persons from being used for criminal purposes, strengthen risk-based supervision, and ensure sanctions for money laundering and terrorist financing offenses are proportionate and dissuasive.
Key Challenges
- Fraud and drug-related offenses account for a staggering 90% of all Dutch proceeds of crime.
- The country faces terrorist financing risks from religious extremism (ISIL and other UN-designated groups) as well as extreme right-wing terrorism.
- Outstanding technical deficiencies, including the regulation of virtual asset service providers, need to be addressed.
Domestic Coordination and International Cooperation
- Domestic coordination between agencies and public-private partnerships are a key feature of the Dutch anti-money laundering and counter-terrorist financing system.
- Strong cooperation exists between the financial intelligence unit (FIU-NL) and law enforcement agencies, who regularly use high-quality financial intelligence from FIU-NL, data hubs, and cooperation platforms in their investigations.
- The Netherlands has also shown effectiveness in cooperating with international partners.
Areas for Improvement
- Increase resources to improve risk-based supervision, including addressing unlicensed activity and ensuring proportionate and dissuasive sanctions for non-compliance with preventive measures.
- Prevent legal persons from being used for criminal purposes by improving access to adequate, accurate, and current beneficial ownership information.
- Focus more on reporting and supervision of the timely implementation of targeted financial sanctions for terrorist financing or proliferation financing.
Confiscation of Criminal Assets
- Confiscation of criminal assets is a strategic priority for the Dutch authorities.
- More needs to be done to prevent legal persons from being used for criminal purposes and ensure access to adequate, accurate, and current beneficial ownership information.
Detection, Investigation, and Prosecution of Terrorist Financing Cases
- The country has successfully detected, investigated, and prosecuted terrorist financing cases, primarily involving the funding of foreign terrorist fighters.
- The Netherlands proactively engages with non-profit organizations to avoid their abuse for terrorist financing and de-risking.
Conclusion
While progress has been made, it is clear that further improvement is needed to combat financial crimes in the Netherlands. The country must prioritize strengthening risk-based supervision, improving access to beneficial ownership information, and ensuring proportionate and dissuasive sanctions for non-compliance with preventive measures.