Its recently published annual report for 2025 shows that the FIOD is seeking to keep pace with the ever-changing forms of crime by adopting new ways of working. This is no easy task, given the ever-increasing digitalisation and internationalisation of fraud, whereby data flows can cross national borders in a matter of seconds.<\/p>\n
In 2025, the FIOD devoted most of its investigative hours to combating money laundering, tax offences and customs offences. This was followed by, amongst other things, corruption investigations and bankruptcy fraud. Tax offences include, for example, VAT fraud, concealed assets and BPM fraud.<\/p>\n
From isolated signals to phenomenon-based detection<\/em><\/p>\n To combat these offences more effectively, the FIOD has adopted new working methods. For example, not all cases are now brought before the criminal court, and out-of-court settlements are being used more frequently. Of all the cases handled by the Functional Public Prosecutor\u2019s Office in 2025, 20.6 % were settled by means of a Public Prosecution Service penalty order or a settlement agreement. Such a settlement may also consist of a fine, which may or may not be recovered following the enforcement of the attachment. In my view, this is also being done to ease the pressure on the criminal justice system.<\/p>\n It is noteworthy that the FIOD states in its report that it is devoting less resources to investigating isolated reports of individual cases of fraud, but is instead focusing its efforts primarily on combating \u2018phenomena\u2019 such as excise duty fraud in the tobacco sector or dividend stripping. The FIOD is increasingly looking for links and trends by comparing and analysing different sources of information. This includes information obtained via Report Crime Anonymously (MMA), the Financial Intelligence Unit (FIU), the Tax and Customs Administration and Europol. In doing so, the FIOD also aims to strengthen cooperation with other partners within the anti-money laundering chain. The focus is no longer on how the suspect is punished, but on how to make this type of crime impossible and encourage citizens to comply with tax rules of their own accord.<\/p>\n According to the FIOD, artificial intelligence is also becoming increasingly important in criminal investigations. In 2025, an AI expert group was set up within the FIOD to focus on meeting the requirements laid down by the EU Artificial Intelligence Act. This is a point of concern for the defence. Objectively speaking, indications picked up using AI do not necessarily always lead to a reasonable suspicion of guilt that would justify the use of special investigative methods.<\/p>\n The Cash Compensation Model<\/em><\/p>\n One phenomenon that has recently attracted a little more attention is the Cash Compensation Model. This is a money-laundering scheme in which \u2013 in short \u2013 cash (of criminal origin) is converted into \u2018clean\u2019 bank money. Business owners who need cash then pay a (fake) invoice by bank transfer. The cash received is sometimes used to pay staff in cash. When determining whether this constitutes a form of money laundering, it is important to establish whether, and if so to what extent, the business owner was aware or ought to have been aware that he was facilitating a criminal flow of funds. Given that this business owner transferred funds electronically from his own account, establishing that link is by no means always straightforward. There is also the question of whether the most severe measures should indeed be applied against this business owner. In my view, the business owner who pays the (false) invoice using money he has earned himself is not the one who has gained the greatest benefit.<\/p>\n It is clear that the FIOD considers itself better equipped to combat money laundering. Nevertheless, it must take care not to treat business owners who have been running a business for years too harshly through seizures and other coercive measures. If a business is ruined before it has been established that someone has actually committed a criminal offence, an acquittal or the dismissal of the case is often nothing more than a Pyrrhic victory.<\/p>\n Mr. D.M. Penn<\/p>\n \n ","protected":false},"excerpt":{"rendered":" Uit haar onlangs verschenen jaarverslag over 2025 blijkt dat de FIOD met nieuwe manieren van werken probeert de almaar veranderende vormen van criminaliteit bij te benen. Geen eenvoudige opgave, gelet op de almaar toenemende digitalisering en internationalisering van fraude, waarbij datastromen in enkele seconden van land kunnen wisselen. In 2025 heeft de FIOD het meeste […]<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[11],"tags":[63,64,62,19],"class_list":["post-7260","post","type-post","status-publish","format-standard","hentry","category-strafrecht","tag-cash-compensatie-methode","tag-cash-compensation-method","tag-fiod","tag-witwassen"],"_links":{"self":[{"href":"https:\/\/penn.nl\/en\/wp-json\/wp\/v2\/posts\/7260","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/penn.nl\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/penn.nl\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/penn.nl\/en\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/penn.nl\/en\/wp-json\/wp\/v2\/comments?post=7260"}],"version-history":[{"count":1,"href":"https:\/\/penn.nl\/en\/wp-json\/wp\/v2\/posts\/7260\/revisions"}],"predecessor-version":[{"id":7261,"href":"https:\/\/penn.nl\/en\/wp-json\/wp\/v2\/posts\/7260\/revisions\/7261"}],"wp:attachment":[{"href":"https:\/\/penn.nl\/en\/wp-json\/wp\/v2\/media?parent=7260"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/penn.nl\/en\/wp-json\/wp\/v2\/categories?post=7260"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/penn.nl\/en\/wp-json\/wp\/v2\/tags?post=7260"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}