WILLEMSTAD – Curaçao will begin carrying out regular, structured investigations into where money laundering and suspicious financial flows occur on the island, following changes to the rules governing the national anti-money-laundering committee. The move is intended to strengthen oversight and demonstrate that the government is responding to recommendations from international watchdogs.
The change does not introduce new legislation but amends existing regulations. The national committee responsible for combating money laundering and terrorist financing already existed, but it is now explicitly mandated to conduct periodic National Risk Analyses and to share the findings with government bodies, banks, and other financial institutions.
The timing of the decision is significant. In June 2024, Curaçao underwent an extensive evaluation by the Caribbean Financial Action Task Force (CFATF), the regional body responsible for assessing compliance with international anti-money-laundering and counter-terrorism-financing standards. The final report, adopted in 2025, contained several critical observations about the effectiveness of Curaçao’s supervision, enforcement, and coordination.
Like other financial centers, Curaçao is required to meet the standards set by the global Financial Action Task Force (FATF) and its regional counterpart, the CFATF. Countries that fail to meet these standards risk reputational damage and closer scrutiny by international banks, potentially affecting access to the global financial system.
The CFATF evaluation concluded that while Curaçao has most of the necessary laws in place, weaknesses persist in implementation and coordination. In particular, the report pointed to shortcomings in systematically identifying national risks and ensuring effective information sharing between institutions. The amended national decree directly addresses these concerns by strengthening the analytical role of the anti-money-laundering committee.
The committee brings together representatives from key institutions, including the Central Bank of Curaçao and Sint Maarten, the police, the Public Prosecution Service, the Financial Intelligence Unit (FIU), the Tax Department, Customs, and the gaming regulator. The Central Bank provides the chair and secretariat. Oversight of the broader policy framework rests with a ministerial steering group that includes, among others, the Ministers of Finance and Justice.
Key findings from the CFATF report underscore the challenges Curaçao faces. While the island has a foundational understanding of its money-laundering risks based on the 2023 National Risk Assessment, sector-specific analyses remain incomplete. Risks related to legal entities, virtual assets, virtual asset service providers, and online casinos have not yet been fully assessed. The evaluation also found gaps in the analysis of terrorist financing risks, particularly in relation to non-profit organizations.
At the operational level, the CFATF noted strong coordination in policy discussions but delays in implementation, especially in international cooperation and asset-freezing procedures. Although Curaçao cooperates with foreign authorities through formal and informal channels, the absence of comprehensive feedback mechanisms and detailed statistics makes it difficult to evaluate and improve effectiveness.
Resource constraints were identified as a recurring problem. Staffing shortages at the FIU, law enforcement agencies, and prosecution services limit the number of money-laundering and terrorist-financing cases that can be investigated and brought to court. The report also pointed to weaknesses in asset recovery, including difficulties in tracing foreign proceeds and shortcomings in the management of confiscated assets, some of which were sold below market value.
While Curaçao has frameworks in place to apply international financial sanctions, the CFATF found inefficiencies in freezing assets subject to sanctions and noted that the non-profit sector lacks tailored, risk-based measures to prevent terrorist financing.
By formally embedding continuous national risk analysis into its anti-money-laundering framework, the government aims to improve oversight, sharpen priorities, and provide clearer guidance to both public institutions and the private sector. Whether the revised approach will translate into more effective enforcement and measurable results will be closely watched by international supervisors in the coming years.