National Threat Assessment 2008. Organised Crime - Politie

Intensification of criminal investigations into money laundering
As a result of the increased focus on international cash flows in the fight against
terrorism, financial institutions have focused their attention on getting to know
their customers. The effect of this ‘customer due diligence’ is that banks assess
high-risk relationships and portfolios more critically and, where required, sell
them off. In addition, there is also a greater focus on the fight against financial
crime, partly because of the murder of several property developers in the
Amsterdam region. The fight against the problems in the Amsterdam red-light
district also makes the criminal investment climate more uncertain. The increased
focus on investigations into unlawfully obtained assets in the form of property
has also reduced the relative anonymity that is a characteristic of the property
market in the Netherlands. All of these developments have a deterrent effect
on criminals who might otherwise invest in property.
Expectations
Based on the crime-related factors, a number of developments are expected. First of
all, economic globalisation makes it relatively easy to invest in property abroad. There
are also a number of Dutch measures in place, such as the Public Administration
(Probity Screening) Act, which make domestic investment in and running of
property more difficult for criminals who are known to the Dutch police. As a result,
criminals who are active in the Netherlands are expected to start investing more
abroad. Despite these developments, the Netherlands will remain attractive for
criminals wanting to invest in property. Apart from the lack of effective supervision,
investments in property that are intended to expand criminal activities are made
wherever the organisation is active. This is why it remains possible that foreign
criminals will be investing more in Dutch property. The Dutch property market is
easily accessible and they are not known to the Dutch investigating authorities.
There is currently no real reason to expect that the obstacles faced by the
investigating authorities will be eliminated within a few years. Expertise must
be built up and the number of agencies involved in enforcement and supervision
will not change, as a result of which the exchange of information and effective
collaboration will not be easy. Effective implementation of the ‘Tackling
Organised Crime’ and ‘Financial and Economic Crime’ improvement
programmes may have a positive effect.
International legislation has made it increasingly difficult for criminals to exploit
property in their own name. It therefore seems plausible that they will be using
complex constructions with (foreign) legal entities more and more often,
including the possibilities offered by all of the various laws and regulations.
Financial service providers are crucial as regards these constructions.
Financial service providers will therefore remain necessary for money laundering
and investing in property.
chapter 3 – Fraud and money laundering
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