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.
A SARA is a systematic assessment of the risks inherent in an institution’s business activities. The analysis typically considers:
The objective is to identify, analyze and mitigate risks in a structured manner and ensure that AML/CFT controls are proportionate to the institution’s risk profile.
Importantly, the scope and complexity of the SARA should reflect the nature, size and complexity of the institution. A small trust office may therefore require a relatively simple risk assessment, while a larger intermediary with international exposure may require a more detailed analysis.
CBCS may request institutions to submit their SARA for review as part of its supervisory process. Institutions are also expected to update the risk assessment regularly, at least annually or whenever significant changes occur in their business model or risk profile.
A properly documented SARA forms the foundation of an institution’s overall AML/CFT compliance framework.
HaVen supports financial institutions in Curaçao and Sint Maarten with the implementation of SARA and broader regulatory compliance requirements.
Our services include:
Our approach is scalable and proportional, meaning it can be adapted to the size and complexity of your organization — from small trust service providers to larger financial intermediaries.
With our local expertise and knowledge of CBCS regulatory expectations, we help institutions build a practical and defensible compliance framework.
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) 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.
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