Tracing criminal money was relatively simple when Michiel Zwinkels, just after the turn of the century, threw himself on the Amsterdam underworld. “Then you had criminals such as Cor van Hout and Willem Holleeder who invested their money in the Netherlands and used a construction with a company in Curaçao. It is no longer that clear. ”
This month, Zwinkels (54) is the chief officer of the Functional Public Prosecutor’s Office. He manages the specialist branch of the Public Prosecution Service, which with 450 employees is responsible for combating money laundering and fraud and compliance with sanctions legislation.
Under the heading ‘Crime may not pay’, that approach has been high on the agenda for years. You can argue about the degree of success. In the Netherlands annually 16 billion euros be laundered, Utrecht University calculated in 2018.
It is money that “could have potentially been taken away,” said the Court of Audit in 2022 in a critical investigation. The institute found that since 2010 hundreds of millions of extra have been put into the hunt for criminal money. That investment is earned back, but according to the Court of Audit, only “limits are harvested.”
The OM, the police and tax investigation service FIOD would not collaborate sufficiently. The amount that the Public Prosecution Service takes annually from criminals fluctuates around 100 million euros.
In a meeting room with a view over the Amsterdam IJ, Zwinkels explains the complexity of the hunt for criminal money. “In twenty years, the unraveling of money laundering constructions has hopelessly become much more complex.” And that while in 2025 there is still litigation in matters in which Zwinkels was involved as a starting officer.
At the beginning of this year, the lord Jan-Dirk Paarlberg, who was ‘hostage’ and secured by the state for Holleeder Witwaste. The reason? After a deprivation process from the OM for money laundering, Paarlberg refuses to pay an outstanding debt of 15 million euros.
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The case against Paarlberg dates from twenty years ago. Why do such things take so long?
“You prefer to finish all criminal cases within one or two years, but unfortunately that is not the reality. Certainly in things with opaque constructions, mixing of lower and upper world at home and abroad, it is a matter of long breath. Moreover, in these types of things almost every decision we make is litigated by the suspect. That means that such a case with Paarlberg can take a long time. “
That has to accept society?
“I think it is our duty to see what can be done about it. As a public prosecutor, I played a criminal case with about twenty Hells Angels. That case was made very great, with all possible criminal offenses. In such cases we must choose sharper and not charge as much as possible. For example, if we also prosecute a criminal offense committed abroad, you will have a delay for a year and a half because of the required international legal aid.
“At the same time, the long term shows that we do not give up with such a case as that of Paarlberg. The moment there is a judicial judgment about a deprivation of criminal money, we really want to collect that money. That can sometimes take a long time, but is important for credibility. “
We see that money is looking for places with less supervision via underground banking. And that is where real money laundering begins
The annual figures of your public prosecutor always appear to be a considerable difference between the money on which seizure was seized (371 million in 2023) and which was actually taken away (95 million in 2023).
“You can’t always take everything away where you impose batter. Part of the money sometimes goes to the tax authorities or abroad when we have seized internationally. Also we cannot always prove all the criminal offenses on which that seizure is based. I think we should not base our success too much on the package result. That joins the discussion. “
What do you measure success on?
“I am more about disturbing the structures that make criminal money flows possible. The way in which this money enters society has become an ecosystem, which goes in many ways. Sometimes large amounts are laundered through international companies. And in other cases, criminal money is spent locally in small quantities and many people are involved. ”
The image of the criminal who has cash in the barn or drives through the city to inspect its real estate is outdated?
“Real estate is still interesting for criminals, but it really invests much more subtly. We still see that it is being purchased through foreign investment companies.
“In addition, criminal money seeps into society in all sorts of ways. The term undermining is often used, but in my opinion the emphasis is too much on drug crime. Organized crime also focuses on healthcare fraud, environmental fraud or online scams.
“This really earns a lot of money, which is often partly invested in drug trafficking. And through tricks, investments are also made in crypto currency to conceal the criminal origin of money. But the undermining is exactly how all that criminal money disappears into our society.
“Because the upper limit of cash transactions is becoming increasingly lower, you also see more and more very cash transactions. Criminals no longer buy a car of 100,000 euros with cash, but lease them and then pay the monthly term in cash. We see that kind of lease or hire -buy transactions more and more often. ”
Recent investigation by the police does it show that criminals do business mutually through a parallel financial system of underground banks?
“Criminals do indeed use underground banking to pay each other or strip each other against each other.
“But that’s not the whole story. Underground banking is no more than moving cash from one place to another. That is not yet white. It still has to be from the lower world. We see that money via underground banking is looking for places with less supervision. And that is where real money laundering begins. That means that cash is made giral and then gets an apparently legal destination. “
Do you have a concrete example of how that works in practice?
“We recently had a successful undercover process in which an agent asked money laundering to get cash in an account in Canada. That money was first moved to Hungary by the suspects. Via a corrupt bank employee, that cash money was deposited into a bank account and then transferred to China. And a Chinese trading company has transferred it to Canada.
“Another example is a system in which Chinese students in Europe with cash from underground bankers, for example, in PC Hooftstraat, expensive bags, watches and jewelry. Those things then go to China to be sold there. For example, this cash issued in the Netherlands gets an apparently legal origin in China. This way of money laundering becomes Daigou mentioned: Chinese for ‘buying on behalf of another’. “
That sounds like criminal money is being washed very fragmented.
“Precisely. There is not one way, there are many hundreds of ways. The agreement is that criminal money always flows. That also makes it so difficult to tackle. That is why you have to focus on structures that make money laundering facilitated. Our studies show that more and more internationally collaborate between criminal groups and state actors from countries such as Iran and Russia. We see that international financial systems that are used for sanction discharge and terrorism financing are also used for money laundering of criminal money. A country like Iran has many years of experience with evading sanctions, which is knowledge for criminal groups also important. ”
In the Netherlands, many measures have been taken against money laundering in recent years. In addition, banks are forced to report many more suspicious transactions. Does that have an effect?
“Banks criticize the fact that they have to report so many unusual transactions: that would lead to nothing. That is a misconception. Reports do not always lead to a criminal investigation, but they are incredibly important to gain insight into the ecosystem.
“For example, on the basis of those many millions of reports by the Financial Intelligence Unit [waar banken ongebruikelijke transacties melden] A system of money laundering discovered: the so -called cash compensation model. That brings together the supply and demand for cash. Drug criminals often sit with cash they want to lose. This is successful with clients in labor -intensive sectors such as the construction, horticulture and transport sector, where staff – usually labor migrants – are regularly paid in cash, so that less or no tax has to be paid.
“We can still say from a lot of criminal money: that goes abroad. But this is in the capillaries of our economy. And it corrupts on all sides: it ensures unfair competition, the Tax Authorities are being flested and it increases the chance of labor exploitation. ”
In Italy there is better cooperation: the fight against the Mafia is a task of governments at all levels
It is striking from your descriptions that criminal money is looking for increasingly complex routes. Does that make you despondent?
“It doesn’t feel that way for me. Twenty years ago I was working on a concrete case as an officer of justice. Now I focus on the system. “
To what extent do you have the tools to tackle that system?
“Criminal law is limited and always afterwards. We have to look differently for tackling criminal money flows. My plea is that there must be a national strategy. The Netherlands has all kinds of thresholds that prevent different parties from working. It works differently in a country like Italy. There, combating the Mafia is a task of governments at all levels.
“That is not the case in the Netherlands and that is why we cannot share much information on the basis of privacy legislation. For example, if a municipality wants to view a court judgment in an investigation into a permit application from a suspicious company, it simply has to look for on rechtspraak.nl between the anonymous judgments. “
And malicious parties benefit from that?
“Absolute. There must be better cooperation in the Netherlands to tackle criminal money and we can use more help from the legislator for that. For example, what we see in almost all matters is abuse of companies. The supervision of legal persons in the Netherlands is completely fragmented. The Chamber of Commerce Recently ringed the bell about this. She sees that all kinds of suspicious companies are founded, but can’t do anything about it herself.
“Another example, same problem: it is very easy to request a citizen service number and then fraudulent. That starts by applying for a bank account for which you need such a citizen service number. We see groups that have entire structures, including citizen service numbers and Chamber of Commerce registrations, ready to sell to other criminals. My call to politics: work on that. “
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