Combating money laundering: state in 2013

We have audited whether the Minister of Finance and the Minister of Security & Justice (V&J) have improved the measures taken to combat money laundering since our previous audit in 2008. We concluded that the Ministers have invested in strengthening capacity, expertise and information exchange but they cannot yet say to what effect.


No insight into risks and results

The Ministers have no insight into the main money laundering risks or the results of combating money laundering. Yet the data are available. As a result:

  • the Ministers cannot steer the organisations involved optimally;
  • the Ministers cannot render proper account to the House of Representatives;
  • the Netherlands cannot fulfil its international obligations to provide an insight into the effectiveness of combating money laundering. 

Too little insight into what is done with reports of suspicious transaction

The Ministers still do not provide adequate feedback to the reporting bodies on what the investigative authorities do with the reports they receive of suspicious transactions.


We recommend that the Ministers of V&J and of Finance: 

  • Provide an insight into money laundering risks making use of the information already available.
  • Collect information on the activities of organisations involved in money laundering and analyse it in relation to the objectives of combating money laundering. Revisit the studies carried out when compiling the money laundering policy monitor.
  • Clarify which money laundering risks must be eliminated in 2015 and what action will be required from the organisations involved.
  • Inform the House of Representatives in the budget and the annual report or even more frequently of the results of combating money laundering.
  • Provide more feedback on what is done with reports of suspicious transactions.

Response and afterword

We received responses from the Ministers of V&J and of Finance and from some of the organisations involved. They largely agreed with our conclusions and recommendations. The Ministers undertook to inform the House of Representatives more systematically of the results of combating money laundering.