The FIU-Netherlands annual review for 2024 shows how dynamic and complex the fight against money laundering and terrorist financing has become. For organizations that fall under the AML, this report is not only a look back, but also a signal for what is to come. In this blog, we take you through the most important insights and outline the opportunities and challenges for 2026.
What stood out in 2024?
In 2024, FIU-Netherlands processed no fewer than 3.48 million reports of unusual transactions, almost double the number in 2023. It is striking that the number of transactions declared suspicious actually fell to 118,408. This emphasizes how important the professional judgment of gatekeepers remains when reporting transactions.
In addition, FIU-Netherlands identified a number of persistent phenomena:
- Abuse of legal entities to conceal ownership or facilitate criminal activities.
- Third-party payments, where a third party makes the payment, which can be both legitimate and fraudulent.
- Real estate constructions for money laundering and exploitation.
- Fraud and corruption, including healthcare fraud and VAT carousel fraud.
An important turning point in 2024 was the approval of the European anti-money laundering package, including the establishment of the Anti-Money Laundering Authority (AMLA). This package brings greater uniformity, stricter sanctions, and an expansion of the sectors subject to supervision.
What does this mean for 2026?
The coming years will be characterized by enhanced cooperation and technological innovation. A new pilot for joint transaction monitoring is expected in 2026, in collaboration with banks, FIU-Netherlands, and regulators. This offers opportunities for more efficient detection, but also raises questions about privacy and GDPR compliance.
In addition, we are seeing trends such as:
- Digitization and AI in compliance processes, which brings both opportunities and risks.
- Stricter European regulations (AMLR, AMLA, AMLD6) that require proactive adaptation of internal processes.
- More emphasis on ESG compliance and transparency, in addition to traditional AML obligations.
Would you like to know how your organization can meet the new requirements while working more efficiently?
Schedule an introductory meeting with our team today and discover how we can take your compliance to the next level.
