WILLEMSTAD – Curaçao's Council of Advice has raised legal and procedural concerns over the government's plan to rapidly introduce new sanctions legislation designed to strengthen measures against terrorism financing and money laundering.
The proposed reforms were drafted after an evaluation by the Caribbean Financial Action Task Force (CFATF), which found that Curaçao was not yet effectively implementing the 40 international recommendations on combating money laundering, terrorism financing and the financing of weapons of mass destruction. As a result, the country must report on its progress in March and September 2026.
Although Curaçao has not been placed on an international black or grey list, it remains under enhanced monitoring and must demonstrate that identified deficiencies are being addressed.
The Council of Advice criticized the government for invoking urgency despite the international evaluation having been announced well in advance. It also noted that the Social Economic Council (SER) was not consulted before the proposal was drafted, warning that mandatory advisory procedures should not routinely be bypassed by citing time constraints.
The advisory body also identified legal concerns regarding a proposal to allow members of the committee responsible for the terrorism sanctions list to begin meeting before completing mandatory security screenings. According to the Council, existing law requires security clearances to be completed before individuals may perform confidential duties.
Another point of contention is the proposed implementation date. The government wants the new sanctions rules to take effect one day after publication, while the current National Sanctions Ordinance requires a two-month period between publication and entry into force. The Council argues that this statutory requirement cannot be overridden by a lower-level decree.
The government has indicated that it intends to proceed with the temporary arrangements while separately working on amendments to the higher-level legislation. However, until those legal changes are finalized, uncertainty remains over whether all of the proposed measures can legally take effect immediately.