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Financial Inclusion and Anti-Money Laundering: A Look at Aruba’s Regulatory Framework
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Aruba, a small island nation in the southern Caribbean, has made significant strides in promoting financial inclusion and combating money laundering and terrorist financing. The country’s regulatory body, the Financial Intelligence Unit of Aruba (FSA Aruba), is responsible for ensuring that financial institutions and designated non-financial service providers comply with anti-money laundering (AML) and combating the financing of terrorism (CFT) regulations.
Complying with AML/CTF Regulations in Aruba
Aruba’s AML/CTF system is based on the Financial Action Task Force’s 40 Recommendations to Combat Money Laundering, Terrorist Financing, and Proliferation. To comply with these regulations, financial or designated non-financial service providers must adhere to specific requirements outlined in the State Ordinance for the Prevention and Combating of Money Laundering and Terrorist Financing.
Requirements
- Conducting customer due diligence (CDD) or enhanced CDD when a business relationship or transaction poses a higher risk of money laundering or terrorism financing.
- Reporting unusual transactions to the FIU, which is responsible for collecting, processing, and analyzing data to identify and prevent money laundering and terrorist financing.
What are My AML/CTF Reporting Obligations?
Service providers in Aruba are required to report any unusual transaction that has been executed or planned as soon as they become aware of its irregular nature. An unusual transaction can be identified using both objective and subjective measures.
Objective Measures
- Transactions reported to the police or ministry of justice.
- Transactions made by or on behalf of individuals or organizations listed on verified sanctions lists.
- Wire transfers greater than or equal to 500,000 Aruban Florins (Afl).
- Cash transactions greater than or equal to 25,000 Afl.
- Cash transactions greater than or equal to 5,000 Afl if the entity is a casino.
Subjective Measures
- Transactions that could potentially be related to money laundering or terrorism financing.
An unusual transaction report must include specific information such as:
- Type and number of the client’s identity document
- Type, timing, and location of the transaction
- Sum, place of origin, and source of funds used in the transaction
- Circumstances that suggest the transaction is unusual
Aruba’s AML/CTF Framework
Aruba’s AML/CTF framework is crucial in promoting financial inclusion while preventing money laundering and terrorist financing. The country’s regulatory body, FIU Aruba, plays a vital role in ensuring compliance with these regulations and identifying potential risks.
As a FATF-listed country with strategic AML deficiencies, Aruba has taken steps to address these issues and strengthen its regulatory framework.