{"id":55613,"date":"2026-11-04T15:09:42","date_gmt":"2026-11-04T14:09:42","guid":{"rendered":"https:\/\/www.altares.be\/?p=55613"},"modified":"2026-11-04T15:09:44","modified_gmt":"2026-11-04T14:09:44","slug":"from-healthcare-fraud-to-mortgage-fraud-who-is-behind-the-file","status":"publish","type":"post","link":"https:\/\/www.altares.be\/en\/blog\/compliance\/van-zorgfraude-tot-hypotheekfraude-wie-zit-er-achter-het-dossier\/","title":{"rendered":"From healthcare fraud to mortgage fraud: who is behind the file?"},"content":{"rendered":"

Part 6 of 6 in our series on compliance lessons from the FIU Annual Report 2025.<\/em><\/p>\n\n\n\n

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.<\/p>\n\n\n\n

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>: a complete file only provides a reliable basis if you know where the information comes from and who it relates to.<\/p>\n\n\n\n

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Healthcare fraud: documents make a scheme look credible<\/h2>\n\n\n\n

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.<\/p>\n\n\n\n

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?<\/p>\n\n\n\n

Interesting read:<\/strong> Recognising a front company: key warning signs and checks<\/a><\/p>\n\n\n\n

Mortgage fraud: the influence of invisible intermediaries<\/h2>\n\n\n\n

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.<\/p>\n\n\n\n

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.<\/p>\n\n\n\n

Supplier screening: three questions about your supporting documents<\/h2>\n\n\n\n

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:<\/p>\n\n\n\n