Frequently asked questions about when to file a report
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Yes. If you believe a transaction is unusual, you should report it to FIU-the Netherlands, regardless of whether it is a completed transaction or merely an intended transaction.
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Indicators of unusual transactions are listed in the 2018 Implementation Decree for the Money Laundering and Terrorist Financing (Prevention) Act (Wwft) (Uitvoeringsbesluit Wwft 2018 [in Dutch]). These indicators differ per reporting entity. The page on reporting groups gives an overview of the various indicators per reporting group. If in your view a transaction meets one or more of the indicators that apply to your reporting group, you must report that transaction to FIU-the Netherlands.
If you have questions about how to interpret a given indicator, you can ask your Wwft supervisory authority. This page shows which supervisory authority is responsible for your reporting group. This division of roles is addressed in more detail in the FAQ “What is the role of the Wwft supervisory authorities in relation to FIU Netherlands?’’.
Conviction for sanctions evasion through the export of dual-use goods
In this case, we examine a report submitted by a bank. Analysis of an unusual transaction gave rise to a suspicion of sanctions evasion through the export of dual-use goods to Russia.
Large-scale fraud and money laundering via cryptocurrency
When police stopped a driver for using a mobile phone while driving, they unexpectedly discovered tens of thousands of euros in cash inside the vehicle. This triggered preparations for a criminal investigation, and the investigation service submitted an information request to FIU-the Netherlands.
Joint financial intelligence advisory: illegal procurement of dual-use goods by Russian end-users
In the aftermath of the unjustified invasion of Ukraine by the Russian Federation (Russia), the financial intelligence units[1] of the Netherlands (FIU-NL) and Canada (FINTRAC) received reports from a variety of sources describing the suspected illegal export, or attempted export, of dual-use goods to Russian end-users in violation of current sanctions or export control-related legislation.
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.
Annual review 2023
Numbers, trends and phenomena of 2023