In 2026, the Financial Supervision Authority (BFT) will launch a thematic investigation into advisors involved in international structures. These structures are complex business and financial constructions that operate across borders. It is precisely this complexity that makes them vulnerable to abuse by criminals. Identifying the ultimate beneficial owners (UBOs) is often a challenge, which increases the risks of money laundering and terrorist financing.
Why is the focus on international structures?
International structures are regularly used to conceal cash flows, mask origins, or evade supervision. Criminal organizations use complex trade flows, such as trade-based money laundering, or underground banking networks to mix illegal funds with legal turnover. This makes it appear as if the money comes from normal business activities, when in reality it is criminal money. This undermines the rule of law and strengthens organized crime.
Your role as gatekeeper
As a tax advisor, accountant, or administrative office, you are designated as a gatekeeper. You are expected to conduct client due diligence and monitor transactions, especially for international clients with increased AML risks. The BFT investigates whether these obligations are being properly complied with. In doing so, they look at, among other things:
- Client-related risks such as complex ownership structures.
- Geographical risks such as locations in high-risk countries designated by the European Commission and the FATF.
What can you do right now?
The thematic study emphasizes how important it is to have your compliance processes in order. A well-designed customer due diligence process and continuous monitoring are crucial to limiting risks and complying with the AML obligations. This is not only a legal obligation, but also a way to protect your organization against reputational damage and financial sanctions.
Schedule an introductory meeting
SCOPE FinTech Solutions has several products that can strengthen your gatekeeper role, so that you are prepared for the BFT investigation.
Schedule a no-obligation introductory meeting today. Together, we will look at how our compliance solutions can support your organization.
