{"id":17472,"date":"2025-06-20T06:49:56","date_gmt":"2025-06-20T06:49:56","guid":{"rendered":"https:\/\/www.jaeger.nl\/witwassen-2-0-van-sporttas-naar-smartphone-de-jacht-op-cryptogeld\/"},"modified":"2025-07-24T10:00:35","modified_gmt":"2025-07-24T10:00:35","slug":"witwassen-2-0-van-sporttas-naar-smartphone-de-jacht-op-cryptogeld","status":"publish","type":"post","link":"https:\/\/www.jaeger.nl\/en\/witwassen-2-0-van-sporttas-naar-smartphone-de-jacht-op-cryptogeld\/","title":{"rendered":"Money laundering 2.0: From cash-filled bags to smartphones \u2013 the legal hunt for crypto funds"},"content":{"rendered":"\n
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Money laundering Is not what it used to be. The sports bag full of cash has given way to digital wallets. Anonymous exchange services and mixers make crypto assets appear hard to trace, but the Dutch Fiscal Information and Investigation Service (FIOD) actively investigates these digital money flows. We frequently encounter such cases in our tax and criminal law practice.<\/strong><\/p>\n\n\n\n

For those suspected of crypto-related money laundering, the playing field has changed radically. Not only have the authorities\u2019 technological capabilities improved significantly, the legal landscape has also shifted. In this blog, I discuss this new reality\u2014as outlined in the FIOD\u2019s 2024 Annual Report\u2014and what it means for the defence.<\/strong><\/p>\n\n\n\n

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From Blockchain to Evidence<\/strong><\/h2>\n\n\n\n

In its 2024 Annual Report, the FIOD gives explicit attention to digital financial crime, alongside VAT fraud, which our colleague Thijs Droog addressed in a previous blog<\/a> (in Dutch). The FIOD refers to cryptocurrencies as a \u201cstructural component of the criminal financial ecosystem.\u201d Mixers, privacy coins (hard-to-trace assets such as Monero), and decentralised exchange platforms play a central role in this.<\/p>\n\n\n\n

The FIOD positions itself as a technical specialist. Staff are trained in blockchain analysis, AI tools are deployed to analyse seized data, and the FIOD cooperates with international law enforcement agencies and, within the Netherlands, with units such as the Police’s High Tech Crime Team (THTC). In 2024, for example, two major cryptocurrency exchanges, Cryptex and pm2btc<\/a> (in Dutch), were taken offline. To seize assets, the FIOD worked with Chainalysis and Tether.io. The message is clear: cryptocurrencies are no longer untraceable. Asset seizures can render digital assets inaccessible for years, and often they are sold off immediately\u2014or even confiscated permanently. It is wise to be prepared and take preventive measures before it is too late. <\/p>\n\n\n\n

The International dimension<\/h2>\n\n\n\n

Crypto knows no borders\u2014and neither does law enforcement. In 2024, the FIOD handled 272 international mutual legal assistance requests involving crypto as a key element. We regularly see clients confronted with the freezing of wallets or digital assets abroad, even without any prior suspicion or charges in the Netherlands.<\/p>\n\n\n\n

This raises important questions about international evidence: how was it obtained? Was the right to a fair trial respected\u2014particularly in jurisdictions such as China or Russia? Every suspect has the right to have their case heard by an independent and impartial tribunal within a reasonable time, and to be given the opportunity to mount a proper defence.<\/p>\n\n\n\n

From suspects to ‘facilitator’<\/strong><\/h2>\n\n\n\n

The FIOD no longer focuses solely on the traditional suspect. Increasingly, so-called “facilitators” are targeted as well. Examples include:<\/p>\n\n\n\n