On the use of false and forged* invoices: we often encounter them in our analyses of unusual transactions. Forgery is a crime in itself and can additionally be used to facilitate money laundering. That is why it is subject to reporting obligations.

The analysis in this case focused on a corruption file. An employee of company A made payments to subcontractor B within existing project budgets. The invoices used for this purpose contained descriptions that referred to ongoing projects.

Payments for private project

However, subcontractor B deposited these amounts into an account belonging to a private project of the employee of company A. These unusual transactions were discovered by the accountant of subcontractor B who reported it to FIU-the Netherlands. The report stated that, in the financial administration, incoming transactions were accounted for differently than the corresponding outgoing transactions.

Invoice of unprovided services

Further investigation by the investigation services revealed that the employee of company A had close ties with employees of subcontractor B. They mutually awarded each other projects, including transfers under false pretences to the account of the private project of the employee of company A.

The invoices used by subcontractor B turned out to be fake: the services listed on the invoices were not actually provided.