FATF mutual evaluation urges Belgium to strengthen effectiveness, resourcing, and virtual asset oversight

In December 2025, the Financial Action Task Force (FATF) published its mutual evaluation of Belgium’s measures to counter money laundering, terrorist financing, and proliferation financing. The assessment reflects Belgium’s framework and implementation at the time of the on-site visit in January and February 2025.

A central conclusion is that Belgium is technically largely compliant with the Financial Action Task Force Recommendations, following legislative and regulatory reforms since the previous evaluation in 2015. However, the evaluation states that significant improvements are still needed to strengthen effectiveness in several important risk areas. One of the areas explicitly highlighted is virtual assets, including the absence of a designated authority to license and supervise virtual asset service providers, which the evaluation describes as a very high-risk sector without adequate oversight.

The evaluation notes that Belgium has a generally satisfactory understanding of its money laundering and terrorist financing risks, supported by national risk analyses that are regularly updated. At the same time, it states that understanding should improve in several areas, particularly regarding risks linked to virtual assets. It highlights prominent risk areas including virtual assets, drug and cash trafficking, professional money launderers, and organised crime networks. It also states that Belgium sees a high degree of interconnection between criminal activities, with increasing links between money laundering and terrorist financing.

On terrorist financing, the evaluation identifies Belgium’s main threat as involving ex-foreign terrorist fighters and radicalised individuals. It points to micro-financing as a relevant channel, including through new payment methods and small cash transactions.

Resource constraints are a repeated theme. The evaluation describes a persistent lack of resources allocated to combating money laundering and states that this affects Belgium’s ability to effectively investigate and prosecute both money laundering and predicate offences. It calls for a strategic approach based on clear priorities and supported by adequate resources, aimed at comprehensively tackling major crime patterns.

The evaluation describes institutional and operational cooperation in anti-money laundering as generally effective, but states that coordination in counter terrorist financing could be improved. It notes the value of more closely associating terrorist financing expertise with terrorism expertise. International cooperation is described as active, including regular and fairly systematic use of informal cooperation and numerous collaborations with foreign partners. However, the evaluation states Belgium should improve the collection of statistical data on mutual legal assistance and other formal cooperation, noting that incomplete data across public prosecutors’ offices makes it difficult to demonstrate systematic implementation in all cases, especially outside Brussels.

Supervision and preventive measures received mixed findings. The evaluation assesses the main supervisory authorities for financial institutions as effectively supervising market access, but states that detection of illicit activities is limited, particularly for hawala transfers and virtual assets. It also finds that financial supervisors generally understand risks and that supervision is generally adapted to risk levels using a risk-based approach. However, it notes very limited use of administrative sanctions, combined with almost non-existent or anonymous publication of decisions, which it says weakens deterrence and the educational effect of enforcement. It also states that supervision in non-financial sectors is fragmented and uneven, with limited inspections despite high non-compliance rates, and it calls for strengthened human and technical resources, particularly for higher-risk sectors such as diamond dealers.

On transparency and beneficial ownership, the evaluation notes that Belgium’s beneficial ownership register supports a multi-pronged approach to access beneficial ownership information and is a useful tool. It also stresses the importance of verification measures to ensure the information recorded is accurate and up to date.

Financial intelligence is presented as a strength with clear limitations. Belgium’s financial intelligence unit, the Cellule de Traitement des Informations financières, is described as playing a key role in producing financial intelligence at operational and strategic levels and largely meeting the operational needs of competent authorities. However, the evaluation states that the information technology tools available to the financial intelligence unit are insufficient and that the use of financial intelligence by competent authorities for money laundering purposes is also insufficient.

In investigations and prosecutions, the evaluation states that, due to resource constraints, Belgium has prioritised money laundering cases based on the profitability of opening an investigation. It says this approach does not orient investigations and prosecutions toward complex cases, but rather toward cases where assets are immediately and easily available. In asset recovery, it notes that Belgium has a comprehensive legal framework for seizure and confiscation, but states that the results achieved are not commensurate with national policies and priorities and Belgium’s risk profile.

Following the assessment, Belgium received a roadmap of key recommended actions to complete within three years. These include allocating resources and effective technological tools to authorities responsible for investigating and prosecuting money laundering, implementing a strategic approach to address major money laundering and terrorist financing risks, and specifically targeting transnational organised criminal networks involved in money laundering and terrorist financing. Based on its effectiveness and technical compliance ratings, Belgium is placed in enhanced follow-up and is expected to report back on progress.

Source: Belgium's measures to counter money laundering, terrorist financing and proliferation financing