by Oscar Pirlot
Abstract: Since the early 2000s, renewable energy has been booming. In the context of the climate emergency, the European Union has made it a priority; for promoters, it’s a real windfall. As a result, the market is attracting a myriad of private players drawn by tempting profitability and generous subsidies. And everyone wants a piece of the pie.
But this growth has its dark sides: developers operate in a labyrinthine sector, growing at a frantic pace, where complexity clouds transparency… and opens up gaps. In other European countries, these gaps have already been exploited by criminal networks.
So, what’s the situation in Belgium? The Walloon market, theoretically well-monitored and protected, is not immune to attempts of infiltration. Authorities, systematically lacking resources, are often more reactive than proactive. And risks – of money laundering, fraud, and corruption – emerge wherever vigilance weakens.
An investigation into a flourishing, lucrative… and highly coveted market.
Since the early 2000s, renewable energies have been booming. With the climate in a state of emergency, the European Union has made it a priority, while promoters have turned it into a golden opportunity. In fact, the market is attracting a myriad of private players, lured by tempting profitability and generous subsidies. And everyone wants a piece of the cake.
But the boom has its dark side: developers are operating in a labyrinthine sector that is growing at a frenetic pace, the complexity of which undermines transparency… and opens up loopholes. And in other European countries, these loopholes have already been exploited by criminal networks.
So what’s the situation in Belgium? The Walloon market, theoretically well monitored and protected, is not impervious to infiltration attempts. The authorities, with their systemic lack of resources, are often more reactive than proactive. And the risks – of money laundering, fraud and corruption – creep in wherever vigilance is lacking.
An investigation into a flourishing, lucrative… and coveted market.
The “Lord of the Wind” breathed his final breath in the summer of 2024. Vito Nicastri, a former electrician who became the baron of wind power development in Sicily, took with him some of the secrets of his dazzling rise. The rest, the Italian authorities have long understood it: Nicastri was not only a pioneer of green energy, he was above all the figurehead of Matteo Messina Denaro, the Sicilian mafia boss (also recently deceased).
With money from Cosa Nostra and a solid network of political connivances, Nicastri built a wind turbine empire across the peninsula, while redistributing part of the profits to the mafia clan. When the assets were seized, the Italian judicial authorities found around a hundred villas, 66 bank accounts and no fewer than 43 companies operating in the wind and photovoltaic energy sector. And a few big cars, too. Even Electrabel, now Engie-Electrabel, found itself exposed: an investigation by Apache media revealed that in 2008, the company had acquired 90% of the shares in a wind farm in Sicily… built and owned by Vito Nicastri.
This scenario was possible because it grew on fertile ground: a fast-growing sector, flush with public subsidies, highly deregulated and difficult to monitor. Italy, like other countries, saw in the energy transition the promise of a new Eldorado, and so did criminal organisations.
What about Belgium? Apart from the presence of organised crime, Belgium shares a number of vulnerabilities with these countries: rapid development, private investment, low transparency of financial movements, a multiplication of players, fluctuating subsidies, cascading subcontracting… A range of flaws which, if not considered as such, could open the door to similar infiltrations.
This investigation focuses on the Belgian (and especially Walloon) renewable energy market, and more specifically on the wind power sector, a symbolic and strategic pillar of the energy transition. It explores the structural weaknesses that make this market permeable, the signals that point to potential risks, and the way in which the authorities are trying – or not – to respond to them.
Favourable winds
Twenty-seven years after the first wind turbine was installed in Wallonia, and despite a period of uneven growth, the sector is still making good money. First, for the owners of exploitable land. Against a backdrop of climate crisis and energy transition, ambitions are on the increase, but the amount of available land is dwindling. As a result, prices are soaring. Whereas the first leases were negotiated at €2,000 or €3,000 a year for the use of a plot of land, today owners can expect developers to pay them up to €20,000 or even €25,000 a year per wind turbine. A good investment for developers, if we consider that a mast can generate net profits of around €190,000 a year, according to calculations by Tchak magazine.
And if windmills are springing up everywhere, it’s because they have to meet increasingly pressing targets. At European level, the REPowerEU plan, launched after the start of the invasion of Ukraine, calls on Member States to further accelerate the development of green energies, in the hope of achieving carbon neutrality by 2050, but also to severely reduce the Old Continent’s dependence on Russian gas. And Belgium is a poor performer, with only 13.8% of its energy consumption coming from renewable sources by 2022 – compared with 60% in Sweden.
In response, the ambitious Walloon region has set its targets for wind power in Pax Eolienica II. It hopes to achieve annual production of 6,200 GWh by 2030. In 2024, the Region produced around 3,000 GWh. A mirage of a target, then, given that new installed wind power capacity reached 100 MW in 2024 for the fourth year running, whereas more than 150 MW would need to be installed annually to meet the targets (such a leap only occurred in 2010, with 163 MW of new capacity installed).
Pro-environment associations have often criticised the anarchic management of the sector’s development. Some refer to it as ‘burying one’s head in the sand’. Clear mapping of areas with wind energy potential, as envisaged in 2013 and then abandoned, is a necessity, but has yet to see the light of day. The regional authorities will, however, have to publish it by July, in order to comply with the European directive adopted several months ago. Instead, developers are operating in a climate of fierce competition, where the policy is ‘first come, first served’.
The Walloon Parliament recently adopted a number of proposals to put an end to the endless appeals before the Council of State. These include an obligation for developers to open their projects’ capital: a maximum of 25% for citizens and a maximum of 25% for local authorities… which should help to reduce the number of systematic disputes.
However, despite its broad ambitions, the wind energy sector in Wallonia remains marked by a certain opacity. Each new project calls into question the boundaries of the market, and the many players involved (developers, intermunicipal companies, citizens’ cooperatives, etc.) operate in a landscape of changing rules. The complexity of a wind farm project’s journey – from prospecting for land to dismantling the masts, between public resistance and political leverage – increases the sector’s vulnerability. Not only does it fuel public distrust, it also exposes the sector to more serious risks.
Risks in the gears
There is no shortage of examples in other countries: such a boom is not without risk. The sustained, rapid and uncoordinated growth of the sector creates loopholes that can undermine its development, but also open the door to criminal infiltration.
By looking elsewhere to understand what is happening in Wallonia, this section explores the risks associated with three key facets of wind energy development: financial arrangements and movements (money laundering or post-money laundering risks), subsidy mechanisms (fraud risks), and the administrative and political labyrinth of a wind energy project’s path (corruption and conflict of interest risks).
As many vehicles as wind farms
Twenty-seven years still after the first wind turbine was installed, and now that it has been replaced (the average lifespan of a tower is 20 years), the Walloon Region has 589 windmills (as at 31 December 2024), grouped together in no fewer than 154 projects. And while there are a moderate number of developers with multiple projects in Wallonia, the wind farms are almost all housed in separate companies. These structures, known as Special Purpose Vehicles (SPVs), enable developers to isolate the financial risks associated with each project, facilitate their resale and securitise the assets (in other words: transform the expected revenues into financial products that can be resold). Here is a first layer of vagueness: a high number of companies means a high number of annual accounts, directors, meetings and balance sheets. In addition, SPVs can be set up in a number of ways, but the prevailing form in the sector is the Société Anonyme (SA), which by definition guarantees the anonymity of its shareholders.
This complexity reflects the considerable financial expertise of the players in the market. While wind power development can generate significant profits, it has to be recognised that it is not a risk-free sector. The multiplication of factors of uncertainty – climatic conditions, public protest, insurance, costly dismantling, etc. – requires solid financial and viability studies. Revenues, on the other hand, depend mainly on the price of electricity and the subsidies that go with it.
Against this backdrop, SPVs are a godsend: they make it possible to compartmentalise risks. If a holding company makes risky financial decisions, its SPV can continue to operate. And conversely, the failure of an SPV does not necessarily make the shareholders or the parent company liable. For investors, this is a way of protecting themselves, but also – by necessity – of making themselves less visible.
Jean-Claude Delepière, former director of the Cellule de Traitement des Informations Financières (CTIF), which fights money laundering in Belgium, highlights the opacity of the financial movements linked to these structures: “Small local companies are set up – as happens in the construction industry, with subcontractors – and then they are bought out. […] From the moment it becomes fragmented, and you have small parties, there’s always a risk because it gets lost and that can justify transactions that get lost. What worries me most about this kind of process is ‘when are we going to carry out controls… Do we really give a damn?’
In research from 2021, students at Bocconi University in Milan looked at mafia infiltration strategies in the renewable energy sector. They explain: ‘Often, investment is made through ‘corporate vehicles”, companies that appear to be legal and have their papers in order, but which are in reality a means of obtaining – through non-transparent practices – the necessary land use rights, authorisations and certificates, as well as modifying invitations to tenders. These companies then sell the rights to other companies, both national and international, and make huge profits from these exchanges”. According to the same study, in Italy, the network of political influence of these structures forces connivance with crime, which is seen as the only way to gain a foothold in the market.
In Belgium, SPVs are often sold – either partially or entirely – transferred from one actor to another, or handed over, sometimes to foreign entities. For example, nearly all of the wind farms developed by the Walloon company New Wind are hosted in separate SPVs. New Wind handles prospecting, negotiation, and filing the permit applications. Once the permits are obtained, it leaves the construction and operation of the wind farms to its sister company, Elawan Energy Wallonie, the Walloon subsidiary of the Spanish wind energy operator Elawan Energy, which is itself majority-owned by the Japanese financial group ORIX. The Henriet family, which founded New Wind in 2008, had already created Green Wind in 2002, which was acquired in 2007 – along with its three wind farms – by EDP Renewables, a subsidiary of the Portuguese energy group EDP and a direct competitor of Elawan Energy. Later, EDPR sold Green Wind and its wind farms to Nadara, another player in the sector.
On top of that, there are holdings – investment structures often based abroad – that hold shares in certain Walloon companies or those active in the region. As a result, identifying the big winners of these complex arrangements becomes rather… complex.
Especially since 2022, when public access to the UBO (Ultimate Beneficial Owners) database, which identifies the final beneficiaries of companies, was significantly restricted following a decision by the European Court of Justice. A real “blow to financial transparency,” according to our colleagues at Le Monde. Consequently, it has become even more difficult for journalists, researchers, or citizens to find out who is really behind certain projects. Luxembourg, a haven for many parent companies and holdings, has also tightened access to its registers.
Dubious investments
And then, conversely, Belgian money also finances renewable projects elsewhere, through bank investments. And green energy is booming. For instance, BNP Paribas promises that by 2030, 90% of its energy-related financing will go to “low-carbon” projects. The European Investment Bank (EIB) and BNP have recently partnered to inject €8 billion into European wind energy, in support of the RePowerEU plan. Belgian banks, often criticized for financing fossil fuel projects, are multiplying promises of investments in sustainable initiatives, both in Belgium and abroad.
Michel Claise, member of GRECO (Group of States against Corruption) and former investigative judge specialized in white-collar crime, states that even though banks have shown a will to clean up their practices since the 1990s, there is a lack of rigor: “There’s not really any control over bank investments. Fines are imposed sometimes, yes, but it’s really exceptional.”
The case of HSH Nordbank in Germany clearly illustrates the issue. This public bank, majority-owned by the Länder of Hamburg and Schleswig-Holstein, financed a massive wind farm in Calabria, Italy, to the tune of €200 million. This park, seized by the Italian judiciary in 2012, is believed to have been used to launder proceeds from drug trafficking and extortion by the Arena mafia clan, which controls the region, through a network of companies in Germany, Italy, Switzerland, and San Marino. Wiretaps revealed contacts between the clan and representatives of the bank, even though the bank denies any involvement. This case, among others, raises the question of the rigor of due diligence (legal, financial, and ethical checks) that companies and financial institutions must perform in order, among other things, to protect the legal economy.
One might also wonder why certain organizations would want to infiltrate a market so far removed from their core sector, and what economic interest they would have in doing so. In this regard, it’s useful to distinguish between money laundering – which seeks to inject illegally obtained profits into the legal economy, to make them usable and clean – and post-laundering investments, which are straightforward placements of already-laundered funds from illegal activities. Michel Claise draws the line as follows: “The question is: it’s worthwhile if it brings returns. But if it brings enormous returns, it’s no longer the laundering machine itself – it’s the investment of the laundering.”
And the two can overlap. The wind farm in Isola di Capo Rizzuto, Calabria, in which HSH Nordbank was involved, was, according to the Italian judiciary, used to launder money from the Arena clan’s drug trafficking and extortion activities. But it also served, like all mafia-controlled energy infrastructures in Italy, to reinforce their presence in those regions by taking control of key sectors (as has also been the case in waste management). These infiltrations, beyond their economic dimension, help mafia clans to strengthen their networks of political complicity. Jean-Claude Delepière (CTIF) confirms: “By gaining this power, you also gain political power over certain regions. There’s a network that doesn’t stop, and that starts from the ground up. […] So that’s the real issue: infiltration into the economy in the pursuit of power, not only to increase financial profit, but above all to gain decision-making power.”
Enticing subsidies
In the early 2000s, spurred by European ambitions, member states quickly put in place support mechanisms to accelerate the transition to renewable energy sources and enable the emerging sector to become competitive with fossil fuels. Some countries opted for a “feed-in tariff” system, guaranteeing producers a purchase price for their green energy over a long period (sometimes up to 20 years).
Belgium, like Italy, chose to implement a “green certificate” system. The Walloon Region began applying it on January 1, 2003. Under this system, the state awards energy producers one green certificate – of variable value but always above the guaranteed minimum price of 65 euros – for every megawatt-hour (MWh) of green electricity produced. These certificates are then sold to distribution operators and electricity suppliers, who are legally required to purchase a certain number of them to meet their quotas (otherwise, they must pay a penalty to the state).
While the issuance of these certificates – based on market conditions, such as the price of electricity and the cost of wind technology – has been set to zero since 2023 for new wind projects (projects launched before 2023 retain the scheme they were granted under), the system long served as a valuable source of guaranteed income for developers; a true safety net. In a 2013 study on the links between clean energy and dirty money in Italy, conducted by Transcrime and the Catholic University of Milan, the researchers state: “Usually, EU countries’ incentives aim to offset the production costs of wind energy. There are only three countries where the level of support is significantly higher than production costs: Belgium, the United Kingdom, and Italy.” The study attributes this to risk premiums, an immature green certificate market, and inadequate certificate validity.
In 2021, a research by the media outlet lavoce.info demonstrated that the growing interest of Italian criminal organizations in the sector was reinforced by the generous green certificate mechanism. As proof, they pointed to the number of turbines installed in regions with high levels of organized crime, which fluctuated with the value of the incentives. The study shows a significant increase in the number of installations in regions with a strong criminal presence during the period 2007–2012, the most generous in terms of subsidies. No such increase was observed in regions with low criminal presence.
In Wallonia, on the photovoltaic side, the generosity of the system triggered a speculative bubble in the early 2010s, the consequences of which were reflected in consumers’ electricity bills and are only now beginning to fade. This bubble was the main factor leading to a reform of the support mechanism in 2014 and the end of new green certificates for solar installations under 10 kW.
Alongside this, some individuals and companies quickly identified weaknesses in the mechanism. In 2011, the company Enfinity falsified validation reports for solar panels installed on the roof of the Balta factory in Oudenaarde, in order to obtain the green certificate rate from the previous year, when it was significantly higher. The amount of the fraud totaled 13 million euros. The company’s director was sentenced to two years in prison, one of which was suspended.
At the end of 2023, fraud committed by a civil servant working in the Energy Division of the Walloon Public Service (SPW) came to light. He is accused of having embezzled between 100,000 and 150,000 euros in green certificates by falsifying data to appropriate numerous certificates, which he then resold.
And beneath the surface, at the scale of a region, the sum of such fraud adds up. In 2022, the Flemish distribution network operator Fluvius estimated the amount of energy-related fraud (green certificates, inspection certificates, illegal electricity use, etc.) in Flanders at 23 million euros. That same year, more than 9 million euros in subsidies were recovered.
Elsewhere, many similar certificate frauds have been uncovered. The Italian case of “white certificates” (meant to support energy efficiency), falsified by fictitious companies and costing the Italian authorities 27 million euros, or the discovery of the “VAT carousel” through which 5 billion euros vanished at the European level between 2008 and 2009 in the resale of “carbon quotas,” show the risks of these parallel, complex, and hard-to-regulate markets, which open the door to criminal infiltration.
The market of complicity
In Belgium, corruption does not make much noise. It is almost difficult to know how to approach it. It is not embodied by infamous Sicilian godfathers, as in Italy where local political corruption is key. It does not have the visibility of major French scandals, nor the minor legal troubles of local elected officials.
Yet, while it may not be spectacular, corruption here is very real – though it likely takes more discreet, more insidious forms. Jean-Claude Delepière (CTIF) highlights it in the very first minutes of our exchange: “If you have a large criminal economy, you have the power to corrupt… including the administration. […] It is clear that this money has a corrupting power that knows no bounds.”
In this respect, the Port of Antwerp has become a symbol of private corruption – discreet, but dangerously effective. There too, complicity is bought to allow drug shipments to pass through. And the operation is running at full speed. One might then ask why the methods used in such a strategic and tightly monitored sector couldn’t also be applied to a booming, complex, and less controlled market.
In Italy, the case of Vito Nicastri is again illuminating. The “Lord of the Wind” was able to build his empire thanks to a significant network of political and business connections. For example, in 2019, State Secretary Armando Siri, a close ally of then Prime Minister Matteo Salvini, was removed from government. He was suspected of having accepted a €30,000 bribe from entrepreneur Paolo Franco Arata – allegedly doing business with Vito Nicastri – to push for measures favoring the installation of wind farms. This example, among others, highlights the density of the web of complicity that forms the influence base of Italian mafias. We’re talking about a system in which economic, political, and at times mafia interests blend together. The result is a stranglehold over the sector – a near-monopoly that allows clans to lock access to land and impose their own companies as subcontractors. And this raises the question: can such systems of corruption be transposed to other territories, on other scales?
In France, small associations against windfarms have made corruption a major pressure tactic, multiplying legal actions against elected officials for conflicts of interest or unlawful participation in wind projects, even going so far as to write a 14-page manual on how to properly initiate lawsuits.
In the United States, as early as 2008, The New York Times warned of the risks of corruption linked to the unchecked boom of wind projects in the New York area. The newspaper reported on intimidation, conflicts of interest, and local corruption in several rural municipalities, within a context of disorganized sector development.
And in Belgium… In Belgium, according to our information, there are no cases involving the renewable energy sector currently under investigation by the Central Office for the Repression of Corruption (OCRC). “It’s not a priority,” admits an internal source. Hugues Tasiaux, director of the OCRC until April 2025, highlights the difficulty of identifying such phenomena: “Corruption – without tips, we don’t do much. […] It’s an offense that’s very hard to prove, because there’s never any interest for someone to speak out.”
And yet, the wind energy market contains no shortage of vulnerabilities. The very functioning of the sector relies on discreet interactions between public and private actors: negotiating land parcels with property owners and/or municipalities (sometimes resulting in abusive contracts, as shown in a Tchak investigation), impact studies carried out by firms that are officially accredited but commissioned by the developers themselves, the issuing of environmental and urban planning permits by regional authorities, public inquiries (which sometimes overlap in the same municipality), appeals before the Council of State… In short, almost as many risks as there are steps – each one involving administrative discretion, complex files, and numerous actors, potentially opening the door to subtle forms of influence or complacency.
These structural risks raise the question of what control and prevention measures Belgium has put in place. More than that, they call for a firm response from the authorities. But what is the actual situation? Are the systems robust, appropriate, sufficient?
Ramparts and drafts
At first glance, there’s nothing alarming on the horizon: no major alerts from CTIF, no open cases at the Federal Police, according to our information. An open field, or one already quietly occupied? And if a dubious company wanted to invest in wind energy in Wallonia, who would hold it accountable?
On paper, the safeguards exist – and there are many. FSMA, CTIF, OCRC… as many acronyms as there are mechanisms. More on that later. But not everything plays out within the framework itself. The vulnerability of the Belgian system lies less in a lack of rules than in a dispersion of responsibilities. The tools are there, but the financial means are lacking. On that, everyone agrees. And when controls do exist, they’re often fragmented, siloed, and rarely coordinated across institutions.
Hugues Tasiaux (OCRC) sums it up: “It’s easier to manage something locally, since you’ve got a public prosecutor, a police unit, and two or three investigative judges, one or two of whom are financial specialists. When you work in a supra-district entity, you’re at the crossroads of too many jurisdictions […], and each one has its own priorities. When a case comes in, it pushes another one out. So it’s very complicated. Aside from bouncing from case to case like a magic ball, it’s hard to handle a file from A to Z.”
So there’s no need to force illegality. The Belgian system allows you to slip right through the cracks of its layered institutional millefeuille.
On paper
In theory, the network of institutions meant to oversee the development of the wind energy sector in Belgium appears fairly well structured. Each stage of a project, from the permit application to the dismantling of the turbines, is framed by authorities and control mechanisms.
Single permits (covering both environmental and urban planning aspects, for projects with an installed capacity over 3 MW) are issued by the Regions, in coordination with the relevant municipalities and based on impact studies conducted by accredited firms. Appeals against decisions can be filed, either with the competent ministers or before the Council of State.
The economic regulation of the market is handled by the CREG at the federal level, with support from the CWAPE in Wallonia. The Walloon Public Service (SPW) Energy department is responsible for granting green certificates in the Region. Technical standards are defined in the wind energy reference framework, updated in 2024.
The market is monitored by the Financial Services and Markets Authority (FSMA), suspicious activity is handled by the Financial Intelligence Processing Unit (CTIF), and the Central Office for the Repression of Corruption (OCRC) investigates corruption suspicions downstream.
In addition, a few legal mechanisms are meant to strengthen the sector’s security: companies are required to declare the ultimate beneficiaries of their activities in the UBO (Ultimate Beneficial Owners) register, although this has not been publicly accessible since 2022. Companies also have a duty of due diligence – careful attention to potential negative impacts on human rights and the environment – both in their own operations and throughout their subcontracting chain. Banks, for their part, are required to report any suspicious financial flows to the competent authorities… and the number of reports is skyrocketing: in 2023, 63,753 new cases were submitted to the CTIF.
In this regard, Michel Claise points to the structural overload weighing on the CTIF: “This is a total mess, we are horribly permeable: there are far too many reports to handle. [Those] who govern us have decided to once again include simple tax fraud among the offences targeted by money laundering laws, which then allows banks to completely flood the CTIF. It’s very bad, it’s not thought through… There’s no expert consultation for this kind of decision.” And here, you can sense the gears beginning to grind.
On the ground
In practice, the complex architecture of the competent authorities, combined with a structural lack of resources, can have a perverse effect: everyone stares at their own feet, without real coordination.
The Region grants permits without necessarily knowing whether the CTIF has received a report about one of the investors. SPW Energy, in charge of subsidies, focuses on production figures but does not examine the legal structures or subcontractors selected for the projects, nor who will ultimately benefit from the revenue inflated by the certificates. The CREG monitors market balances without systematically knowing the origin of the funds flowing through the system. There is no map of the numerous SPVs scattered across Wallonia – which makes it difficult to identify repeated patterns or worrying concentrations – nor is there any obligation for public access to subcontractor selection.
Another issue is that Belgian authorities lack foresight and risk prevention. “The problem we have in Belgium is that we are reactive, not proactive,” says Hugues Tasiaux (OCRC) bluntly. There is no risk analysis for emerging markets, “and that’s the whole problem,” he continues. “When I took over the office, there was a clerk, a strategic analyst… and so there were analyses that could be done. At CentrEX [the expertise center, ed.], about seven or eight months – a year ago – we put an analyst back at the center of the board, who’s now starting to dig into databases, conduct risk assessments, do the kind of work we used to do. But it’s like reinventing the wheel!”
The most recent sectoral risk analyses from the CTIF on money laundering don’t focus on the renewable energy market.
The problem: the Belgian side’s lack of proactivity and coordination isn’t necessarily mirrored by the other side. Jean-Claude Delepière (CTIF) reminds us of the criminal networks’ capacity for engineering: “This renewable energy market is obviously one more godsend for all criminal organizations – especially the biggest ones: drug cartels – who not only have banks, but also financial experts. And that’s something we often forget: we think of drug crime as little guys with Kalashnikovs… no! They have legal offices, teams of international experts…”
Lessons from elsewhere
Elsewhere, some countries have taken the issue head-on. In Italy, anti-mafia strategies – from prevention to enforcement – are evolving and being structured around the recognition of mafia presence as a structural component. This has led to specific sectoral analyses, dedicated branches within the Direzione Investigativa Antimafia (DIA), and systematic anti-mafia checks (such as anti-mafia declarations for companies seeking access to public contracts or subsidies…). No such mechanisms exist in Belgium in this form, and denying the structural presence of criminal organizations on our territory may come at a high cost.
Enrico Fontana, head of the “Environment and Legality” Observatory at Legambiente, Italy’s largest nonpartisan environmental association, highlights three main risk factors in the development of renewable energy: the lack of planning and citizen participation, inadequate oversight of intermediary companies operating in the market (sometimes without real capital or proper technology), and the underestimation of the entrepreneurial capabilities of mafia-type criminal organizations.
According to him, the first preventive countermeasure lies in the “transparency of procurement processes for the construction of all types of facilities – from wind and solar to biomass – and in the accessibility of data to enable citizen oversight.” Which, as we’ve seen, is not a strength of the Belgian system.
Finally, since criminal networks operate across borders, the fight against criminal infiltration must also take place at the European and international levels. Fontana emphasizes the importance of bodies like OLAF (the European Anti-Fraud Office) and the European Procurement Office, which ensures transparency in public procurement at the European scale.
The Financial Action Task Force (FATF), which leads global efforts against money laundering and terrorist financing, evaluates countries on the strength of their systems to combat these issues. In 2015, the FATF wrote the following in its evaluation of Belgium: “In the financial sector, the supervisory authorities have generally identified the main high risks. However, the understanding of risks is not sufficiently continuous due to a lack of controls carried out, particularly on-site inspections.” The next FATF evaluation is scheduled for October 2025.
As for corruption, in 2024 Belgium lost four points in Transparency International’s Corruption Perceptions Index, scoring 69 out of 100, which placed it 22nd out of 180 countries. In a report published in March 2025, the OECD noted some legislative progress in Belgium’s fight against international corruption but pointed to a structural lack of resources, the rarity of prosecutions against legal entities, and the mildness of the penalties imposed.
Strengthening the antidotes
Enrico Fontana (Legambiente) sums it up in three words: “Transparency, participation, control – from the proposal of projects to their construction – are three antidotes to the infiltration of illicit capital, which, along with corruption, have long been the entry points for criminal networks across all European countries.”
Certainly, the risks of infiltration exist. The renewable energy sector – and its wind energy market – has what it takes to attract criminal organizations, bringing with them the risks of money laundering, fraud, and corruption.
But Belgium has the means to strengthen its antidotes. Transparency can be improved through better access to beneficial ownership registers (UBO, Ultimate Beneficial Owners), a clearer overview of market players, greater openness around SPVs, and the development of a genuine map of Wallonia’s wind energy potential.
Participation can be enhanced by making it mandatory for project capital to be open to cooperatives and municipalities – leaving less room for unwanted investments – by encouraging greater citizen involvement in site selection, and by taking opposition more seriously.
Control, in turn, requires a firmly proactive stance. The authorities have the tools, and highly competent people. Both Jean-Claude Delepière (CTIF) and Hugues Tasiaux (OCRC) agree on that. What remains is to strengthen resources and establish systematic, lasting, and proactive collaboration – at regional, federal, and European levels.
In the meantime, vigilance is essential. “Mafias have evolved,” warns Fontana. As some sectors become more tightly regulated in Italy, criminal organizations are shifting their focus: “Today, their attention is on biomass, biofuels, and carbon credits – partly because, in traditional sectors like wind and solar, the blind spots of twenty years ago have disappeared.” Between the persistent loopholes in traditional markets and the new breaches in emerging sectors, criminal organizations are mapping out their own zones of opportunity. It is up to Belgium to draw its own map – with the challenge of no longer reacting, but anticipating, by shedding light on the grey areas of its green energy sector; by sharpening its vigilance upstream, before the cracks become open doors.
S-INFO PODCAST
The S-INFO podcast gives voice to the winners of the S-INFO Award, who share how they carried out their investigations in collaboration with civil society organisations. Guided by their mentors, the journalists take us behind the scenes of their work—exploring methods, challenges, and partnerships that made their stories possible.
Listen to Oscar Pirlot: