The Central Bank of Curaçao and Sint Maarten (CBCS) continues to strengthen its supervision of regulated financial institutions in Curaçao and Sint Maarten. Recent circulars issued by the CBCS show a clear trend toward stricter monitoring of AML/CFT compliance obligations, including the implementation of a proper SARA (Systematic Integrity Risk Analysis) and the timely submission of annual financial statements and regulatory reports.
For institutions such as trust companies, insurance intermediaries, money transfer businesses, and other supervised entities, compliance expectations are becoming increasingly demanding.
The Central Bank of Curaçao and Sint Maarten (CBCS) has introduced new guidance on the Systematic AML/CFT/CFP Risk Assessment (SARA). This framework is part of the CBCS’ risk-based supervisory approach and aligns with international FATF recommendations for combating money laundering and terrorist financing.
All institutions supervised by the CBCS — including trust service providers, insurance intermediaries, money transfer companies and credit institutions — are required to implement a structured risk assessment process covering money laundering (AML), terrorist financing (CFT) and proliferation financing (CFP) risks.
The CBCS has emphasized that financial institutions must maintain an up-to-date and institution-specific SARA. A generic or outdated risk assessment is no longer considered sufficient.
The SARA framework is intended to demonstrate that an institution properly identifies, assesses, mitigates, and monitors integrity risks related to money laundering, terrorist financing, and proliferation financing (AML/CFT/CFP). The CBCS increasingly expects supervised entities to show clear documentation, governance, and practical implementation of their compliance measures.
In practice, many organizations struggle with:
The CBCS has also increased its use of information requests, compliance reviews, and on-site inspections to assess whether institutions are genuinely operating in accordance with AML/CFT requirements.
In addition to AML/CFT supervision, the CBCS recently announced a stricter enforcement approach regarding the late submission of annual accounts and prudential reports.
Institutions that fail to meet statutory filing deadlines may face more direct supervisory measures and enforcement actions. According to the CBCS, timely reporting is essential for effective supervision and financial sector integrity.
This development highlights the importance of maintaining proper internal governance, planning, and compliance monitoring processes.
The overall direction is clear: regulatory expectations in Curaçao and Sint Maarten continue to increase. Supervised institutions are expected not only to have policies in place, but also to demonstrate that compliance frameworks are actively maintained and effectively implemented.
A proactive approach toward compliance is therefore becoming increasingly important.
Need help with your SARA? Feel free to contact us for practical advice and support.
Founder & Director
Erik van Engelen, RA
vanengelen@havensxm.com
+1721 534 2833
Director
Erik Spek
spek@havensxm.com
+31 6 10917418
The Central Bank of Curaçao and Sint Maarten (CBCS) continues to strengthen its supervision of regulated financial institutions in Curaçao and Sint Maarten. Recent circulars issued by the CBCS show a clear trend toward stricter monitoring of compliance obligations, including the timely submission of annual financial statements and regulatory reports.
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