Participatory enforcement in combating economic crimes: Insights from tax offences, money laundering and sanctions evasion

Abstract This paper explores the evolving role of participatory enforcement in combating economic crimes, focusing on tax offences, money laundering and sanctions evasion. It examines how EU law increasingly relies on private actors as agents of transparency, particularly through reporting obligations aimed at disclosing and addressing these crimes. Through case studies, the paper highlights the decentralisation of enforcement mechanisms. In the context of taxation, it investigates obliged entities' and—at times—citizens' reporting obligations in combating tax evasion and/or avoidance. Regarding money laundering, it examines both obliged entities as well as the dual role of employees in financial institutions as both mandated reporters and voluntary whistleblowers. For sanctions evasion, the paper explores the unprecedented expansion of reporting duties in the post‐Ukraine conflict era, including the EU's reliance on both citizens and (non‐EU) sanctioned individuals. By analysing these areas of EU law, the paper evaluates the balance between compliance obligations and individual rights and examines the conditions underpinning disclosure requirements. It also assesses the consistency of the EU's reliance on non‐state actors to report economic crimes, raising critical questions about the present and the future of its enforcement mechanisms.