Strengthening Belgium’s Financial Response to Organised Crime

Over the past decade, those charged with fighting financial crime have been on a mission to expand their focus from understanding the problem, passing laws in response and building national law enforcement and criminal justice structures, to delivering results, in the form of arrests, prosecutions and asset confiscation. The chief driver of this requirement to demonstrate effectiveness is the global anti-financial crime watchdog, the Financial Action Task Force (FATF), which conducts evaluations of countries on a seven- to ten-year cycle. These evaluations shine a bright light on the effectiveness of a country’s efforts, not merely their technical compliance with the watchdog’s standards.

The latest report on Belgium’s effectiveness was published in December 2025, and painted a mixed picture of a system that ‘is technically largely aligned with the FATF Recommendations’ but with a ‘persistent lack of resources’ allocated to anti money laundering (AML), which ‘has an impact on the effectiveness of the law enforcement approach implemented by the competent authorities’. Thus, the report notes: ‘The resources available to the authorities to investigate and prosecute money laundering and predicate offences are not commensurate with the challenges Belgium faces.’

Reinforcing that report, Belgium’s new national security plan (‘Plan National de Sécurité (2026–2029)’/ ‘Nationaal Veiligheidsplan (2026–2029)’)’introduced a new goal of breaking the criminal business model, recognising that this is a key constituent of the fight against organised crime (‘Briser le modèle économique criminel constitue un élément essentiel de la lutte contre la criminalité organisée’). The goal is clear, but how will Belgium achieve it, what barriers exist, and what lessons could the country learn from its Western European neighbours?

A 2024 report from Europol, ‘Decoding the EU’s Most Threatening Criminal Networks’, makes clear the challenge faced by both Belgium and the EU more broadly. The report identifies over 800 high-threat networks across the EU, noting that more than 150 operate in Belgium. For example, Antwerp is one of Europe’s primary ports of entry for cocaine, and the country more broadly acts as a logistics and finance hub for organised crime, facilitated by the cross-border access enabled by geography.

Belgium’s national strategy recognises that if profit is at the heart of organised crime, then ‘following’ and ‘catching’ the money should be at the heart of the response.

This paper argues that Belgium’s challenge is not one of capability in isolation, but of integration: aligning tools, systems and policies into a coherent, finance-led response that can adapt to evolving criminal methodologies. It concludes with a set of actionable recommendations designed to support that process.

Methodology

The analysis that follows draws on the discussions from a workshop which took place at RUSI Europe in Brussels, organised by RUSI’s Centre for Finance and Security in March 2026. The workshop explored financial responses to organised crime, situating them within the broader European and FATF context. The workshop convened relevant Belgian policymakers and law enforcement officials, supplemented by insights from other European countries shared by experts from the European Commission.

The report is based on the unattributable contributions of participants in the workshop, supplemented by a review of the aforementioned Belgian FATF Mutual Evaluation and Belgium’s national security plan and relevant Europol publications.

The Financial Tools of Organised Crime

Organised crime in Belgium relies on a mix of traditional and alternative financial systems. In addition to cash and informal value transfer systems (IVTSs), the landscape is further complicated by increasingly sophisticated professional money laundering networks (PMLNs) and crypto payments. Many of these mechanisms operate partially or entirely outside the formal financial system and, as a result, outside supervision, making detection and disruption difficult. As one participant neatly summarised, ‘As a criminal, if you can avoid the bank in Belgium, you walk free without any problem of detection.’

The Role of Cash

Despite sustained efforts to modernise the AML framework in Belgium, as elsewhere in Europe, cash remains king in the criminal underworld and the dominant tool of choice. The full extent of cash-based criminal activities is difficult to capture, as much of it remains unknown, and thus with so many unknown and undocumented activities, the phenomenon's overall scale cannot be assessed.

One reason that large parts of this cash-based activity remain invisible is that authorities’ oversight relies on disclosures from the formal financial system, and the extent to which this monitoring overlaps with cash represents only a fraction of total cash flows. This means that most criminal financial activity occurs beyond the regulatory perimeter. For example, cash plays a key role in sectors that rely on liquidity, such as construction, cleaning and hospitality. At the point at which those sectors interact with the formal, regulated financial sector, criminal cash can easily be blended with licit funds.

Additionally, it was noted at the workshop that there is a lack of control over cross-border cash movements, particularly at airports and ports, where public safety priorities override investment in financial detection activity, further reducing opportunities for disruption and confiscation.

Because most cash-based activities occur outside authorities' oversight, responses are weak. Across Europe, only around 2% of criminal proceeds are confiscated; workshop participants pointed to a similar picture in Belgium, despite universal agreement on the critical importance of cash seizure in disrupting criminal flows. Where penalties are enforced, including imprisonment, they are not seen as strong deterrents for those for whom criminal profit is their motivation.

In short, while the Belgian system is well-equipped to monitor what enters and circulates within the formal financial system, it is less capable of illuminating activity beyond that perimeter.

Informal Parallel Financial Systems

Informal financial systems (often referred to as informal value transfer systems (IVTSs)), such as Hawala, serve legitimate purposes, particularly within diaspora communities, enabling low-cost remittances to regions with limited banking infrastructure. However, their opacity and lack of regulatory oversight also make them attractive to criminal actors.

Like cash, IVTSs represent a significant but poorly understood part of the financial ecosystem supporting organised crime in Belgium. As with cash-based criminal activities, the lack of understanding of these alternative financial trails is exacerbated by the fact that these systems do not intersect with regulated and supervised banks. As a result, they go undetected or remain undisclosed, and thus unreported to the authorities. Participants noted that the lack of cash controls at Belgium’s border to identify and disrupt bulk cash movements – an important element of IVTS transaction settlements – further facilitates the use of IVTSs by criminal groups. Lastly, the fact that these systems are embedded in broader social and economic networks makes them difficult to identify without intelligence on people and communications, rather than just on financial flows.

Money Laundering as a Professional Service

A notable development in recent years is the increased prominence of professional money laundering networks (PMLNs). These actors specialise in the movement and concealment of illicit funds, providing services to a range of criminal enterprises. Rather than laundering their own proceeds, these networks operate as intermediaries, facilitating the financial operations of others.