Part 6 of 6 in our series on compliance lessons from the FIU Annual Report 2025.
A diploma through a recruitment agency. An income statement through an intermediary. Anyone assessing a file sees the documents provided. Less visible is who prepared, collected or checked those documents.
The FIU Annual Report 2025 shows how this division of roles can be exploited in healthcare fraud and mortgage fraud. The examples also offer a lesson for supplier screening: a complete file only provides a reliable basis if you know where the information comes from and who it relates to.
Healthcare fraud: documents make a scheme look credible
In 2025, FIU-Netherlands declared 63 healthcare fraud files suspicious, involving approximately 1,000 transactions in total. The annual report describes how different parties enable a fraud scheme. One arranges companies, while another supplies false invoices or forged qualifications. Together, these documents can create the impression that a service provider has the right staff and the necessary expertise.
A Belgian case from the Social Information and Investigation Service also shows how fictitious invoices conceal reality. They suggested that services had been provided, while they were used to launder criminal proceeds and supply companies with cash for undeclared work. For clients, this underlines the importance of checking the actual delivery: which party provides the service, and what information supports that?
Interesting read: Recognising a front company: key warning signs and checks
Mortgage fraud: the influence of invisible intermediaries
Besides the content of documents, the route they take into the file also deserves attention. In mortgage fraud, FIU-Netherlands describes the role of so-called sub-introducers. These intermediaries guide applications, ensure that false documents end up in files and push for approval. Their names often do not appear in the formal documents, even though they influence the information on which a decision is based.
In supplier assessments, too, several documents may rely on the same source. Suppose you receive a CV, a copy of a diploma and a statement from the intermediary for a hired worker. Everything is consistent. But if that statement is based on the same diploma copy, the qualification has still not been independently verified. The fact that documents agree therefore does not tell you everything about their reliability.
Supplier screening: three questions about your supporting documents
How do you apply these insights to your own assessment? Take one recent assignment and choose a diploma, licence or certificate that was decisive in granting your approval. Then ask three questions:
- Where does the evidence come from? Find out who issued it and through which parties it reached your file. Do different documents rely on the same unverified source?
- Who does the evidence apply to? Check whether it belongs to the person or legal entity actually carrying out the work. A main contractor’s certificate does not automatically cover a subcontractor as well.
- How has the evidence been verified? Where possible, consult the issuing authority or an authorised register. Record what you checked, when and against which source.
Repeat the relevant checks if a different worker or subcontractor is brought in during the assignment. The supporting documents on which your original approval was based may then no longer apply.
Interesting read: Third-party risk: how to determine which suppliers require extra attention
Knowing which company to check
In this check, the identity of the party carrying out the work is an important starting point. With business and ownership data from Altares Dun & Bradstreet, you can identify the legal entity behind a business name and gain insight into ownership structures and corporate relationships. This makes it clear which company you need to request supporting documents from. You then verify their validity and scope with the issuing authority.
Would you like a clearer view of the parties behind your suppliers? Our experts show you how business data strengthens your supplier screening.
