Risk indicators money laundering properties

Municipality of Utrecht

Preventing Utrecht real estate from being used for laundering criminal assets. This approach is part of the citydeal Zicht Op Ondermijning.

Last change on 12th of July 2024, at 9:47 (CET) | Publication Standard 1.0

• Publication category: Impactful algorithms
• Impact assessment: DPIA, ...
• Status: In use

General information

Theme

Public Order and Safety

Begin date

-

Contact information

[e-mail]

Link to publication website

zichtopondermijning.nl

Responsible use

Goal and impact

In practice, it happens that Utrecht properties are used for laundering criminal assets. By applying this algorithm, we want to gain insight into the risk of real estate being used for money laundering. With the aim of preventing and enforcing money laundering of (criminal) money as much as possible. The analysis reveals what proportion of real estate per neighbourhood was purchased with unexplained assets.

Considerations

Results Utrechts Uthiek Assessment: with this Real Estate approach within the Zicht op Ondermijning (Insight into Undermining) trajectory, we reduce the risk of Utrecht real estate being used for money laundering. This contributes to the Safety and Health values of Utrecht residents. If we apply this preventive approach successfully, we prevent the group of vulnerable Utrecht residents from growing. In doing so, we fulfil the value Justice. When applying the algorithm, there is no risk of privacy violation, because it does not work with personal data but with profiles of objects and the results are published at an aggregated level.

Human intervention

The algorithm (with a direct impact on Utrecht residents and their living environment) always serves only as a source of information for an employee, who takes the appropriate next step based on it and the context of the situation. This principle is included in our Utrecht framework Internal Guidelines for Algorithm Application.

Risk management

The Utrecht data scientists, Information and Process Advisors (IPA) and Decentralised Information Security Officers (DISO) within the Utrecht municipality have a controlling and monitoring role in the application of the algorithm, in addition to the employees directly involved. By doing so, we want to prevent the following risks from occurring:

- data leak by making personal data of Utrecht residents publicly available

- algorithm takes a decision completely independently, without the intervention of an employee and without interpreting the relevant context of the situation

- 'function creep' regarding data when applying the algorithm, causing the algorithm to give a distorted picture of what is going on. This can occur because the same type of data is used when applying the algorithm, and the algorithm uses that as confirmation of what comes out as information

Legal basis

Central Bureau of Statistics (CBS) Act

Impact assessment

• Utrechts Uthiek Assessment
• Data Protection Impact Assessment (DPIA)

Operations

Data

Data sets used in the application of the algorithm include the following:

- Ownership and ownership of dwellings (EIGENDOMTAB). This file provides information on the annually determined ownership status of the housing stock;

- Existing Homes for Sale (BKW) transaction file 1995-2016 compiled by the Land Registry. Contains data on all housing transactions between individuals from 1995 to 2016;

- Income of Individuals (INPATAB). This file contains the annualised income of persons on 1 January of the reference year. This file replaces from 2011 the file Integral personal income;

- Household wealth (VEHTAB). Contains data on the wealth on 1 January of the reference year of households belonging to the population of the Netherlands at the end of the year preceding the reference year. This file replaces the Integral Wealth Database (SCHTAB) from 2011;

- Acquisitions from estates of deceased persons (VRKTAB). Inheritances from estates of persons deceased in the reporting year for which inheritance tax returns have been filed.