Netherlands | Publication | 7月 2025
For many years, anti-money laundering (AML) compliance was seen as the exclusive domain of financial institutions. Outside that sector, few companies considered money laundering a material compliance risk. That perception is rapidly becoming outdated. As enforcement authorities have ramped up pressure on traditional gatekeepers—banks, auditors, and other financial intermediaries—these institutions have responded with a surge in suspicious transaction reports. The Dutch Financial Intelligence Unit (FIU) alone received nearly 3.5 million reports in 2024, a 50 percent increase from the previous year. This shift, combined with the sweeping changes introduced by the new European AML legislative package, is expanding the perimeter of exposure. Non-financial companies—often unknowingly—can become entangled in money laundering schemes, especially when tainted funds or assets are introduced through seemingly legitimate transactions. Complex deal structures, third-party payments, and mismatches between buyers and payers are no longer just operational quirks—they are red flags.
The latest FIU report underscores that these risks are not hypothetical. They are real, growing, and increasingly relevant for all sectors. Now is the time for companies outside the financial sector to reassess their risk profiles, strengthen internal controls, and ask: are we prepared?
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:
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:
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 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:
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:
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.
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