WILLEMSTAD - An internal decision document issued by the Central Bank of Curaçao and Sint Maarten in September 2019 provides a detailed and damning account of the circumstances that led to the withdrawal of Banco del Orinoco N.V.’s banking license, offering new insight into one of the most controversial financial collapses linked to Curaçao in recent years.
The 28-page decision, addressed directly to Banco del Orinoco and signed by the Central Bank’s executive management, formally revokes the bank’s license with immediate effect. The document outlines a pattern of misconduct that, according to the regulator, went far beyond administrative shortcomings and pointed to systemic failures, including the use of falsified documents, serious breaches of anti-money laundering rules, and misleading representations about the bank’s financial position .
At the heart of the Central Bank’s findings is the conclusion that Banco del Orinoco repeatedly submitted falsified custody statements and correspondence to create the appearance that it held substantial assets on behalf of clients. These documents were allegedly used to demonstrate solvency and liquidity during supervisory reviews. The Central Bank determined that these representations were not only inaccurate but deliberately misleading, undermining the reliability of the bank’s balance sheet and financial statements .
The regulator notes that multiple international custodians named in Banco del Orinoco’s submissions, including TMF, Amergeris, Vistra, and Farrington, either denied holding assets for the bank or stated that the documents attributed to them were falsified. In several cases, email addresses used in the correspondence did not belong to the institutions in question, or confirmations were sent from non-existent or spoofed domains. According to the Central Bank, these practices continued even after the bank had been formally warned and placed under heightened supervision .
The document also details how Banco del Orinoco attempted to defend itself by claiming that certain assets were held indirectly or for the benefit of affiliated entities. The Central Bank rejected this explanation, stating that the bank failed to provide verifiable proof and that its arguments were inconsistent with earlier statements. The regulator concluded that the bank’s conduct obstructed effective supervision and violated the legal obligation to provide accurate and complete information .
Beyond falsified asset documentation, the Central Bank describes widespread non-compliance with anti-money laundering and counter-terrorism financing regulations. The investigation highlighted customer relationships and transactions involving politically exposed persons, high-risk jurisdictions, and unusually large transfers that were either inadequately monitored or not reported to the Financial Intelligence Unit. In some cases, transfers amounting to millions of dollars were executed without proper customer due diligence or internal approval, despite clear regulatory requirements .
The regulator further identified structural governance failures within Banco del Orinoco. The board and senior management were found to lack effective oversight, internal controls were described as inadequate, and key compliance functions were either understaffed or ineffective. According to the Central Bank, these weaknesses allowed irregular practices to persist and compounded the risks to depositors and the financial system .
In its conclusion, the Central Bank states that it could no longer rely on the accuracy of Banco del Orinoco’s financial reporting. As a result, the bank’s solvency and liquidity could not be verified, creating an unacceptable risk to creditors and the integrity of the financial sector. The regulator emphasized that under Curaçao law, the use of falsified documents alone constitutes sufficient grounds for license withdrawal, regardless of whether criminal proceedings are ongoing .
The decision also makes clear that alternative measures, such as intensified supervision or conditional restrictions, were deemed insufficient given the scale and duration of the violations. The Central Bank concluded that allowing Banco del Orinoco to continue operating would have undermined confidence in Curaçao’s financial system and its reputation as a regulated international banking jurisdiction .
Years after the bank’s collapse, the Central Bank’s decision document provides a rare, detailed look at how regulators assessed the situation internally. It suggests that the downfall of Banco del Orinoco was not the result of a single incident, but of a sustained pattern of misrepresentation, regulatory non-compliance, and governance failure. For depositors and observers alike, the document raises renewed questions about accountability, oversight, and the long-term impact of the case on Curaçao’s financial sector.