F.I.N.A.N.C.E. - Anti-money laundering project


F.I.N.A.N.C.E. is a research project promoted by the legal department of the University of Perugia (Italy) and funded by OLAF (the European Anti-Fraud Office), as part of the Hercule III Programme.

The project is executed in the Netherlands by Robbert-Jan Lugard LL.M. (National Legal Expert) and Mirjam den Haan LL.M. paralegal at Hoens & Souren Advocaten.

F.I.N.A.N.C.E. stands for: Financial Information exchange among Anti-money laundering National investigative authorities: towards a stronger Cooperation in an European legal framework.

The anti-money laundering (AML) project

The project will develop a comparative research study on rules and practices of Financial Intelligence Units (FIU’s) in Europe regarding anti-money laundering. Due to the transnational scope of money laundering, interconnections between FIU’s are necessary to conduct cross-border analysis and investigations of money laundering and its predicate crimes such as fraud and corruption. Therefore this study will focus on the FIU’s located in five member states (Germany, Luxembourg, Spain, Italy and the Netherlands).

Mirjam den Haan
Mirjam den Haan
Robbert-Jan Lugard
Robbert-Jan Lugard









Money laundering prevention and repression

By assembling and comparing information from the different Member States this study will highlight strengths and weaknesses in existing cooperation mechanisms among FIU’s and among other competent national and supranational authorities (e.g. EPPO, OLAF) in criminal investigations concerning money laundering prevention and repression. To this end a team of national legal experts, consisting of scholars and practitioners, has been appointed. Each national legal team will perform a separate national investigation and present their findings in Autumn, 2022.

Aim of the project

Ultimately this project aims to form a foundation of information for future EU commission initiatives for strengthening judicial and inter-institutional cooperation at a European level in the fight against money laundering.

The Dutch research

The Dutch national team aims to gather information regarding rules and practices of the Dutch FIU (Financiële Inlichtingen Eenheid) regarding money laundering. For the purpose of creating an comprehensive understanding this study consists out of five parts, all in relation to money laundering.

  1. The first part entails a concise description of the Dutch law provisions on money laundering.
  2. The second part provides an overview of the institutional setting of the Dutch FIU.
  3. For the third part the Dutch FIU’ access power to information from obliged entities such as central registers, are researched.
  4. The fourth part shows the cooperation with other FIU’s, in particular; the dissemination of information between Dutch FIU and other FIUs.
  5. And lastly, the fifth part pays attention to the cooperation with the Dutch law enforcement and judicial authorities.

The results of the Dutch research will be presented in autumn, 2022 in Perugia.

Parties involved:

a) International
Scientific Committee University of Perugia
(1)   Prof. Vico Valentini
(2)   Prof. Carlo Fiori
(3)   Prof. Enrico Carloni
(4)   Dr. Folco Gianfelici
(5)   Dr. Fabio Siena

b) National legal experts
(6)   Dr. Giovanni Amato (Germany)
(7)   Prof. Silvia Allegreza (Luxembourg)
(8)   Prof. Maria Jose Pifarré de Moner (Spain)
(9)   Robbert-Jan Lugard LL.M. & Mirjam den Haan LL.M. (the Netherlands)