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FIU-the Netherlands

NOW-fraud identified thanks to reporting

During the corona pandemic, the so-called NOW regulation provided financial compensation for Dutch companies with substantial loss of revenue. The government support was specifically intended for paying salaries and keeping staff employed. Through reports of banks and notaries we identified several cases of misuse of the NOW regulation. In this combined case study, you can read about our efforts and findings.

In this case study, facts from several real-life examples were combined to avoid traceability of specific cases.

Through our online reporting system we received a message from an accountant suspecting NOW fraud. NOW fraud means that a company unrightfully received an advance of the NOW support and refuses to return the money. One of our FIU-analysts explains: “In many of the reported cases, there was no or not enough loss of revenue to be eligible for the NOW financial aid. The latter was the case in the message we received.”

No salary payments
“The accountant noticed that the financial aid was not booked as salary for employees. Instead, significant sums were transferred to other companies. Upon questioning the beneficiary, the accountant received only vague and contradictory answers.”

Requesting account statements
Our analyst dived further into the matter. “I started by requesting their account statements at the bank” he explains. “This provides very useful information. For example, whether the company has returned the subsidy in the meantime. If so, no further investigation is required. In our case study, no money had been returned. The next thing I always check is whether the financial aid was used for paying salaries. If that’s not the case, I try to figure out where the money went.”

Other spendings
The analysis revealed that the money was spent on entirely different things. “Overdue payments, purchase of luxury items, cash withdrawals, company investments, you name it. Through another bank account the money was even used to buy real estate.” Because the NOW regulation was specifically issued for salary payments, these spendings catch the eye.

Fictitious employment contracts
Another way our case study committed fraud was by faking the number of employees. “Companies received NOW financial aid based on the size of their workforce. This company reported more staff than it employed. On top of that, some staff members were presumably deliberately let go after receiving the NOW support.”

Collaboration with FIU’s in other countries
Sometimes, NOW money is transferred to bank accounts abroad. “In that case, we collaborate with the corresponding FIU, because we don’t have access to the relevant information. After receiving the name of the bank account owner, we can usually trace the money.”

The importance of reports
The received reports show the extent of NOW fraud. Our FIU analyst states: “This concerns money of all Dutch taxpayers, me included. I sincerely hope that the Investigation Services can recover most of it. Reports of unusual transactions make this work possible and are of utmost importance. With it, all pieces fall into place.”

* The NOW support was an advance payment which entrepreneurs (or their accountant) could apply for, based on preliminary calculations. The regulation continued until mid-2022 and definitive amounts were calculated retrospectively. Since any overpaid amounts had to be repaid first, the whole process took time. Entrepreneurs received ample time to meet their obligations, if necessary, through an instalment plan. For that reason, the NOW fraud investigation could only start much later.