The government has explicitly assigned the detection of money laundering to banks and other gatekeepers such as accountants. They must identify customers, analyze transactions, and report anomalies. This is essentially a public task, but without these parties always having a uniform and future-proof toolkit. The consequence is that each institution develops its own systems, interpretations, and risk models.

Against this background, it is striking that there is now an emphasis on additional access to the BRP. Privacy experts rightly raise questions about this. At the same time, Europe is working on the introduction of the digital identity, the EDI-Wallet, which is expected to be available for all citizens and businesses by 2026 at the latest. Such a digital wallet offers a standardized and controlled way to share identity data, without making databases more widely accessible.

Part of the solution also lies in making e-invoicing mandatory for all transactions in the Netherlands. When invoices are exchanged fully digitally and according to fixed European standards, a uniform data model is created with structured information about sender, receiver, amounts, and VAT. In countries where this is already mandatory, such as Italy and Belgium, the government can almost in real-time detect deviating patterns, such as illogical invoice chains or sudden increases in volume.

If such data is centrally available for oversight, not every bank needs to conduct the same analyses separately. Monitoring of fraud and money laundering can then be organized more consistently and transparently, with less dissemination of privacy-sensitive data. If that step is not taken, a progressively complex system threatens in which powers are expanded, but the structural solution remains out of sight.