Trade in NFTs represents a new market that features virtual goods at skyrocketing prices and apparently little regulation and oversight. With sums of this magnitude at stake, it is inevitable to think about the repercussions of this new market for illicit financial flows control. And indeed, NFTs receive increasing attention in the financial integrity arena. In its ‘2022 Crypto Crime Report’, Chain alysis, one of the most renowned crypto analytics companies globally, identified a growing relevance of NFTs to pursue money laundering and wash trading. This risk was confirmed by the latest virtual assets (VA) report published by the Financial Action Task Force (FATF) in June 2022. There, NFTs have been recognised as one of the key market developments to keep under close watch.

De Financial Intelligence Unit Nederland (FIU) verklaart jaarlijks tienduizenden ongebruikelijke transacties verdacht met behulp van een geautomatiseerde vergelijking met de informatiedatabase (VROS) van opsporingsdiensten. Verdachtverklaring middels VROS heeft enkele potentiële gevolgen voor het onderscheid tussen ongebruikelijke en verdachte transacties, de positie van de FIU en de inbreuk op de persoonlijke levenssfeer van betrokken (rechts)personen.

Criminal organisations use and misuse legal structures in order to launder the money they earn through crimes. Local authorities can unwittingly and unwillingly facilitate crime and money laundering. After all, criminals or people who can be linked to crime and money laundering have to make use of certain legal structures in order to launder their money. They have to apply for permits, they need housing, etc. In order to prevent this misuse of legal structures, the information exchange between law enforcement authorities is necessary, and an administrative, integrated approach to preventing and fighting organised crime is needed. Such information exchange often poses problems in border regions, however, as most of the laws with regard to information exchange between different authorities are written with purely national situations in mind. In border regions, citizens from neighbouring countries often also apply for certain permits if they wish to do business in a municipality. In such cases, obtaining information about these persons is often more difficult because of the lack of (inter)national legislation. Hence, border regions have a greater chance of being misused for money laundering purposes. This article presents and explains the results of a project by the Euro-regional Information and Expertise Centre (EURIEC). The project aims, inter alia, to analyse the possibilities and “bottlenecks” with regard to the (cross-border) exchange of data, with a view to enhancing the administrative approach to organised crime.