Samenvatting

Trade-Based Money Laundering (TBML) is a phenomenon in which assets of criminal origin are moved and/or concealed and/or layered through trade transactions. Recently, police organizations and other parties have paid more attention to this issue. As a trading nation, the Netherlands is vulnerable to this form of money laundering. In this article, the author discusses the challenges in detecting TBML. TBML is difficult to detect because it can theoretically involve all goods and has various manifestations. Relevant information is scattered among various public and private agencies. Third-party payments and the frequent international component of TBML further complicate detection. Exchanging data between Customs and FIOD could contribute to faster detection of TBML activities. Matching customs data at the international level could also lead to earlier detection.