Working method for fighting subversive crime

What exactly is subversive crime, which organisations engage in the fight against it, how do they collaborate, and what could be the impact of this on people whose data are processed? You can read it on this page.

On this page

This is subversive crime

There is no such thing as a definition of subversive crime that is used by everyone. But subversive crime often entails organised, invisible crime. The aim is usually to make (a lot of) money.

Subversive crime is not limited to the underworld. On the contrary, criminals often make use of legitimate businesses. For example by:

  • buying property for laundering money that was made illegally;
  • using hotels, cafes and restaurants for laundering money made in drug trafficking.

Subversive crime can also extend to the government. And in this way lead to corruption and loss of integrity.

Read more about Subversive crime on the website of the Dutch central government (in Dutch).

These organisations fight subversive crime

Several organisations are engaged in the fight against subversive crime. These are, among others:

  • the police;
  • the Public Prosecution Service;
  • municipalities;
  • provinces;
  • the Tax and Customs Administration;
  • the Fiscal Intelligence and Investigation Service FIOD;
  • the Netherlands Labour Authority;
  • the Immigration and Naturalisation Service IND;
  • the Employee Insurance Agency UWV.

These organisations often collaborate with each other to address subversive crime as effectively as possible. They do this, for example, within one of the Regional Information and Expertise Centres (RIECs).

Collaboration in RIECs

There are 10 Regional Information and Expertise Centre (RIECs) in the Netherlands. These centres focus on the fight against subversive crime. Various (government) bodies are affiliated with the RIECs. These partners all have a different range of instruments for addressing subversive crime. Collaboration in the RIECs ensures that the partners:

  • can more easily share expertise and knowledge among themselves;
  • are given support in an integral approach of subversive crime.

The RIECs do this by acting as a central point for information. And by making it easier for the partners to coordinate their actions. In turn, the RIECs are supported by the National Information and Expertise Centre (LIEC).


  • keeps the RIECs abreast of developments in the field of subversion;
  • coordinates the national strategy for cross-regional crime, such as criminal motor gangs and organised cannabis growers and traders.

Exchange of personal data

An important part of what the RIECs and the LIEC are doing is the exchange of (personal) data between the various partners. When doing this, both the partners and the RIECs and the LIEC themselves have to meet the requirements of the General Data Protection Regulation (GDPR).

In an advice on the future Data Processing by Partnerships Act (in Dutch), the Dutch Data Protection Authority has criticised such exchange of personal data.

Infringement of privacy

The fight against subversive crime often involves the processing of personal data. This may result in a significant infringement of the privacy and the lives of the data subjects. For example, if:

  • the government imposes measures on the data subject;
  • the data subject becomes the focus of attention of various investigating bodies.

Even if this does not result in concrete measures, the processing has a stigmatising effect. After all, someone is linked with possibly criminal activities.