Published: August 2025
Source: FIU-the Netherlands Annual Review 2024 (released in June 2025)
The Scale of the Problem
The Dutch FIU dropped their 2024 annual review in June, and the numbers are frankly alarming. We’re seeing a massive uptick in criminals using legitimate-looking business structures to move dirty money around. Shell companies, straw owners, offshore setups – all of it is becoming more sophisticated and harder to spot.
The report shows that unusual transaction reports jumped from 2.3 million in 2023 to 3.5 million in 2024. That’s a 50% increase in a single year. And it’s not just volume – the schemes themselves are getting layered and complex in ways that make traditional compliance checks look almost quaint.
Hennie Verbeek-Kusters, who heads up the FIU, put it bluntly: “The abuse of legal entities for criminal purposes is intensifying and becoming more complex.”
She’s not wrong.
What Exactly Is a Sham Company?
Before we dive into the details, it’s worth defining terms. A sham company (sometimes called a shell company, though there are technical differences) typically has minimal real economic activity. According to research from Eurofound on fraudulent contracting across the EU, these entities are often set up to fulfill a specific contract, register some employees on paper, and then disappear once the job is done.
The pattern usually goes: managers resign, the upfront capital vanishes, bankruptcy gets declared, and nobody ever pays the social security contributions or taxes. Often these companies are just one piece in a bigger cross-border subcontracting puzzle.
What the FIU Found
Here’s what stood out from the 2024 report:
- 3.5 million unusual transaction reports filed (up from 2.3 million the year before)
- 118,408 suspicious transaction reports actually forwarded to law enforcement
- 16,306 case files opened for investigation
- A clear trend toward multi-layered structures involving several front companies, offshore connections, and payments coming from third parties who shouldn’t be anywhere near the transaction
You can read the full report here (PDF)
or check out the summary on the FIU website
Common Tactics
The report breaks down several typologies that keep showing up:
Sham Legal Entities
Pretty straightforward – criminals register companies in the Netherlands or abroad that look legitimate on paper but have virtually no real business operations.
Third-Party Payments
This one’s tricky. You’ll see transactions where the person or company making the payment has no obvious connection to the deal. It makes it really difficult to figure out where money is actually coming from or what it’s really for.
Cash Compensation Models
This is particularly common in construction and logistics. The way it works: subcontractors get paid in cash (already a red flag), then they “reimburse” shell companies through fake invoices. The FIU has a whole knowledge base entry on this model if you want to go deeper.
Real Estate Laundering
Opaque entities buying up properties to park criminal proceeds. Sometimes these properties then get used for other illegal activities – cannabis cultivation, illegal gambling operations, you name it.
What This Means If You’re in Compliance
Look, document verification isn’t enough anymore. The FIU’s findings basically scream that you need to be looking at patterns and context, not just checking boxes.
Red flags you should be watching for:
- Newly registered companies that suddenly have huge transaction volumes (where’s that business coming from?)
- Multiple layers of ownership, especially if they connect to known offshore leak databases
- Payment structures involving third parties where the logic just doesn’t add up
- Real estate purchases that make zero sense given what the company supposedly does
How We Can Help (and Why We Built This)
We built Business Radar specifically because these problems kept getting worse and the tools available weren’t keeping up.
What we offer:
- UBO (ultimate beneficial owner) data from national and international registries
- Visual maps of corporate ownership structures – especially useful when you’re dealing with multi-layered setups that are designed to ocnfuse
- Integration with Offshore Leaks, Pandora Papers, and similar datasets
- Fuzzy matching algorithms for names, addresses, and linked entities (because criminals aren’t exactly meticulous about spelling consistency)
- Screening for adverse media, PEP exposure, and regulatory actions
Our clients use these tools to catch shell company behavior and hidden connections before they become problems. Before they end up in enforcement headlines, basically.
The Broader European Picture
What’s happening in the Netherlands isn’t happening in isolation. The EU just published Regulation 2024/1624, which is pushing toward standardized AML rules across member states, more transparent beneficial ownership registries, and stronger expectations around real-time monitoring.
The regulatory environment is tightening, and frankly, it needs to.
Bottom Line
- Front company abuse is accelerating. Construction, logistics, real estate – these sectors are particularly vulnerable.
- The Dutch FIU’s 2024 review (published this past June) gives us really valuable intelligence on how these schemes are evolving.
- Tools like Business Radar exist to help compliance teams move faster – to detect risky structures, verify what’s real, and act before small red flags become major regulatory issues.
Don’t wait until you’re facing enforcement action to rethink how you’re doing KYC. The criminals aren’t waiting.
See beyond today with Business Radar.