The Expanding AML Perimeter: Why Non-Financial Companies Should Pay Attention

Key Takeaways From the FIU Netherlands 2024 Annual Review

The FIU recently published its Annual Review for 2024. This report offers valuable insights into trends and developments in money laundering, terrorist financing, and other forms of financial crime. Whether you are a multinational corporation, a family-owned business, or a fast growing startup, understanding how these risks are evolving is essential. Not per se because your organization is doing anything wrong, but because you could, often unknowingly, become involved in transactions or business structures that may later attract regulatory scrutiny.

1. A surge in unusual transaction reports

In 2024, the FIU registered nearly 3.5 million reports of unusual transactions (UTs) — a rise of more than 50 percent compared to the previous year. This increase was primarily driven by payment service providers (PSPs), cryptocurrency platforms, and credit card companies. The growth reflects not only higher transaction volumes in these sectors but also increased regulatory attention on reporting entities.

For organizations, this uptick means:

• A higher chance that your transactions or client relationships might be flagged or investigated, even when you act in good faith.
• The need for robust internal processes and documentation to manage risk;
• Timely legal review of client structures and transactions to avoid reputational damage and legal complications.

2. Emerging typologies

The FIU’s report highlights several typologies that are relevant across a wide range of organizations. These structures are not inherently suspicious, but in the wrong context or without proper controls, they can expose your organization to significant risks. 

Key areas to watch out for include:

• Legal entities and strawman constructions: Criminals may use shell companies or foundations to obscure financial flows. Organizations with complex group structures should ensure transparency in ownership and intra-group transactions.
• Third-party payments: While not necessarily illegitimate, these can pose risks when the origin of funds is unclear. Transparency and proper documentation are key.
• Real estate transactions: Complex ownership structures, particularly involving foreign entities, are frequently used to launder illicit funds. Extra caution is advised, especially in cross-border investments.
• Sector-specific vulnerabilities: In sectors such as healthcare, subsidies, fintech, and crypto, organizations may unknowingly facilitate fraud or money laundering. Thorough due diligence is essential.

3. Looking ahead: the new EU AML Framework

A major development in 2024 was the adoption of the new European anti-money laundering package, which includes:

• The Anti-Money Laundering Regulation (AMLR) - Regulation (EU) 2024/1624;
• And the Sixth Anti-Money Laundering Directive (AMLD6) - Directive (EU) 2024/1640;
• The Anti-Money Laundering Authority Regulation (AMLAR) - Regulation (EU) 2024/1620.

The AMLR will apply directly across the EU from 10 July 2027 onwards, while Member States must transpose AMLD6 into national law by the same date. The new EU supervisory authority AMLA, assumed operations as of 1 July 2025, with direct supervision of obliged entities expected to commence as of January 2028.

For larger organizations, this will mean stricter compliance requirements at group level, increased oversight of cross-border transactions and a more coordinated regulatory environment, where enhanced information sharing between FIUs may lead to faster detection and investigation of suspicious international activities. 

It is advisable to begin preparing now by:

• Reviewing compliance policies and internal controls;
• Training staff on upcoming obligations;
• Legally assessing client onboarding and transaction monitoring procedures.

4. The role of data and collaboration in modern financial crime detection

The FIU is investing heavily in technological innovation, including analytics tools such as GoAML and GoFintel. These systems enable the analysis of large volumes of data and the rapid detection of suspicious patterns. At the same time, cooperation with banks, regulators, and foreign FIUs is being intensified. As a result, organizations should be aware that:

• Transactions may be flagged more quickly, even without intent or wrongdoing;
• Transparent documentation and thorough client due diligence are more important than ever;
• Legal support in responding to inquiries or notifications from regulators is increasingly critical.

5. Why awareness and preparedness are your best defense

The FIU’s Annual Review makes one thing clear: financial crime is becoming more sophisticated, more international, and more difficult to detect. Organizations across all sectors—not just banks or financial institutions—can find themselves inadvertently caught up in suspicious transactions or business relationships. This often happens not through any fault of their own, but because they become part of a broader chain of events involving tainted funds or opaque structures. The risks are real, and growing.

To stay ahead, companies in the non-financial sector should take proactive steps now. Begin by mapping your exposure: assess your client base, supply chains, and transaction flows for red flags such as complex ownership structures, third-party payments, or links to high-risk jurisdictions. Equip your teams—especially in finance, legal, procurement, and compliance—with the tools and training to recognize and escalate suspicious activity. Even if not legally required, consider implementing or enhancing internal controls for due diligence and transaction monitoring. And when uncertainty arises, seek legal advice early. These measures are not just about compliance—they are about protecting your business from reputational harm, regulatory scrutiny, and financial loss.

Our team supports clients across all industries—whether you're building a compliance framework from the ground up, refining existing policies, or navigating a complex transaction or investigation. We help you strengthen controls, assess risks, and meet regulatory expectations with confidence.

Feel free to reach out for a confidential conversation about how we can help protect your organization and stay ahead of evolving risks.