WILLEMSTAD – The Central Bank of Curaçao and Sint Maarten (CBCS) has formalized its procedure for rapidly informing banks and other supervised institutions about changes to international sanctions lists, with United Nations updates being communicated within 24 hours of receipt.
The procedure, published on August 13, explains how the CBCS receives and distributes information concerning sanctions imposed by the United Nations, European Union and other jurisdictions.
International sanctions can target individuals, companies, terrorist organizations, senior officials and parts of foreign states. They can be imposed in response to violations of international law or human rights, terrorism and the proliferation of weapons of mass destruction.
According to the CBCS, the Financial Action Task Force (FATF) requires relevant sanctions to be incorporated into national legal frameworks “without delay.” FATF also requires the central bank to proactively inform institutions under its supervision about international sanctions developments because financial institutions serve an important gatekeeper function.
The CBCS receives sanctions information through several channels, including the United Nations, Curaçao’s Directorate of Foreign Relations and De Nederlandsche Bank.
For UN sanctions, the central bank is directly subscribed to the UN sanctions mailing list. Once an update is received, the CBCS says it sends the relevant information to supervised institutions in Curaçao and Sint Maarten through its Secure Infrastructure Access system within 24 hours.
The CBCS also receives monthly sanctions alerts from De Nederlandsche Bank covering changes to UN, EU and Dutch sanctions during the previous month. The central bank then prepares sanctions alerts for Curaçao and Sint Maarten in both Dutch and English and publishes them on its website.
Sanctions originating nationally or from other foreign jurisdictions are communicated to the CBCS through the Directorate of Foreign Relations. These notifications are also forwarded to supervised institutions within 24 hours after receipt.
The central bank stresses that institutions cannot simply wait for a CBCS notification before acting. They are responsible for continuously following developments concerning UN, EU and other targeted financial sanctions.
In Curaçao, UN sanctions apply directly through the National Sanctions Ordinance and Omnibus Sanction Decree Curaçao, while EU sanctions are implemented through the Kingdom Sanctions Law. The CBCS is responsible for supervising compliance with the applicable sanctions legislation.