FinCEN Netherlands Investigates €18M Tax Evasion Network Using Shell Companies and Offshore Accounts

FinCEN Netherlands has launched a large-scale investigation into an alleged tax evasion scheme involving €18 million in undeclared income, channeled through a network of offshore companies and nominee account holders. The central suspect is a 43-year-old Dutch national, Tomé van Elzen, who is believed to have orchestrated a complex financial structure to conceal business earnings and avoid corporate tax obligations over a five-year period.

Background of the Investigation

The case, codenamed Operation White Ledger, was initiated in early 2024 after irregularities were found during a routine audit of Lentari Consulting B.V., a Rotterdam-based marketing firm that reported unusually low taxable profits despite visible international operations and contract inflows.

Cross-referencing data from financial institutions, trade records, and custom declarations, FinCEN’s audit revealed that Lentari had transferred large sums—under the label of “licensing fees” and “digital consulting services”—to Tavora International Ltd., a shell entity registered in the British Virgin Islands.

The Offshore Network

Subsequent analysis uncovered a layered network of at least nine offshore companies in:

  • The British Virgin Islands
  • Belize
  • Luxembourg
  • The Isle of Man

These entities were nominally operated by foreign intermediaries, but in reality controlled by van Elzen through proxies, including close acquaintances and legal representatives listed on forged board resolutions.

Bank statements show that earnings from Lentari’s clients, primarily based in Germany, Sweden, and South Africa, were routed offshore before being returned to the Netherlands via:

  • Personal loans
  • Dividend schemes
  • Real estate purchases

All of which were designed to avoid corporate tax and dividend withholding tax.

Asset Tracing and Seizure

On June 7th, FinCEN executed a coordinated search in collaboration with the Fiscal Intelligence Coordination Unit (FICU), leading to:

  • The seizure of €4.3 million from domestic and foreign bank accounts
  • Temporary freezing of three high-end properties in The Hague and Utrecht
  • Confiscation of four luxury vehicles, including a Tesla Model X and Porsche Taycan
  • Retrieval of digital devices and encrypted documents relevant to the shell structures

Suspected Offenses

The ongoing investigation is focusing on several serious violations, including:

  • Intentional tax evasion under the Dutch General Tax Act
  • Use of fraudulent legal constructions to misrepresent income
  • Violation of transparency obligations for international holding structures
  • Forgery and the use of falsified business documentation

The total estimated tax loss to the Dutch state exceeds €18 million, including unpaid corporate income tax, VAT, and dividend withholding tax.

FinCEN’s Statement

“The use of shell companies, offshore layering, and fake licensing schemes is a well-known tactic in international tax crime,”
said a FinCEN spokesperson.

“We are committed to uncovering these structures and restoring fairness in the tax system.”

FinCEN urges professionals such as tax advisors, lawyers, and accountants to remain alert and report any suspicious client behavior involving international financial flows that appear disproportionate to declared income.

Reminder: Legal Use vs. Abuse of Offshore Structures

While owning or investing in foreign entities is not illegal, using them to deliberately conceal taxable income or to create artificial expenses for the purpose of reducing tax obligations constitutes a criminal offense in the Netherlands.