The Financial Action Task Force (FATF) released its 2025 mutual evaluation of Belgium on December 16, revealing significant gaps in the national framework for combating illicit financial flows. While the nation maintains technical alignment with international standards, the report highlights a critical shortage of human and technological resources within investigative bodies. Belgian authorities must now address systemic weaknesses in virtual asset oversight and the prosecution of complex financial crimes to escape enhanced follow-up status. The evaluation emphasizes that current enforcement levels do not adequately reflect the sophisticated nature of modern criminal networks operating within the jurisdiction. This assessment serves as a formal roadmap for Belgium to strengthen its defense against organized crime and terrorist financing over the next three years.
Table of Contents
Belgian Financial Oversight and the Virtual Asset Gap
The evaluation identifies a major regulatory vacuum regarding the management of digital assets and virtual asset service providers. Despite the high risk associated with these technologies, Belgium has not designated a specific authority to license or supervise entities operating in this sector. This lack of oversight creates a significant vulnerability that criminal organizations can exploit to move funds across borders without detection. Financial supervisors currently demonstrate a satisfactory understanding of traditional banking risks, yet their ability to detect illicit activities in emerging sectors like virtual assets and hawala transfers remains remarkably limited. The absence of a robust licensing framework for virtual assets undermines the overall integrity of the Belgian financial system and prevents the effective mitigation of modern money laundering threats.
Resource Constraints and Money Laundering Prosecution Priorities
A persistent lack of funding and personnel severely impacts the ability of Belgian law enforcement to pursue sophisticated money laundering cases. Investigations are frequently prioritized based on the immediate profitability of the case or the ease of asset recovery rather than the complexity or strategic importance of the criminal network involved. This reactive approach allows professional money launderers and organized crime syndicates to continue operations if their assets are well hidden or difficult to seize. To rectify this, the state must allocate substantial technological and human resources to public prosecutors and the judicial police. Without these investments, the legal system remains unable to tackle the root causes of criminal activities or dismantle the transnational networks that utilize Belgium as a hub for drug and cash trafficking.
Administrative Sanctions and Transparency in Financial Supervision
The effectiveness of the Belgian repressive system is currently weakened by the limited use of administrative sanctions and a lack of transparency regarding enforcement actions. Financial supervisors rarely impose significant penalties, and when they do, the decisions are often kept anonymous or remain unpublished. This practice diminishes the dissuasive effect of the law and fails to provide the necessary educational impact on the broader financial sector. Strengthening the legal framework to allow for more public and severe sanctions is essential to foster a culture of compliance. Furthermore, supervision in non-financial sectors, particularly for high-risk industries such as diamond dealing, is fragmented and suffers from high non-compliance rates due to infrequent inspections.
Strategic Integration of Financial Intelligence and Asset Recovery
The financial intelligence unit serves as a vital pillar in the Belgian anti-money laundering architecture, yet it is currently hampered by outdated IT tools and insufficient integration with other law enforcement agencies. While the unit produces high-quality strategic intelligence, the actual utilization of this data for money laundering prosecutions is suboptimal. Improving the technical infrastructure of the financial intelligence unit is a recommended priority to ensure that data can be processed and shared in real time. Additionally, while Belgium possesses a comprehensive legal framework for the seizure and confiscation of criminal assets, the actual volume of confiscated funds does not align with the national risk profile. A more aggressive and strategically coordinated asset recovery policy is required to ensure that crime does not pay within Belgian borders.
Key Points
- Belgium is now under enhanced follow-up after the 2025 FATF evaluation due to effectiveness gaps.
- The lack of a designated supervisor for virtual asset service providers creates a high-risk regulatory void.
- Severe resource shortages in the judiciary lead to the prioritization of simple cases over complex laundering networks.
- Administrative sanctions lack a deterrent effect because they are rarely used and frequently kept anonymous.
- A three-year roadmap requires Belgium to implement advanced technology and strategic coordination for asset recovery.
Related Links
- Belgium Measures to Counter Money Laundering and Terrorist Financing
- National Risk Assessment of Belgium Financial Intelligence Unit
- FATF Recommendations on Virtual Assets and Service Providers
- European Commission Anti-Money Laundering and Countering the Financing of Terrorism
Other FinCrime Central Articles About Belgium
- Belgium’s $270 Billion Sanctions Dilemma: The Unintended Consequences
- In Belgium, Massive Blow to Money Laundering Network Exposes €54 Million Criminal Scheme
- ING Belgium Handled up to €700k Cash Deposits By Former EU Commissioner Without Blinking
Source: FATF
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