Purpose
Maintain complete reporting obligations, accountable roles, deadlines, review and approval authorities across all applicable Curaçao regulatory authorities: the Central Bank of Curaçao and Sint Maarten (CBCS), the Financial Intelligence Unit (FIU Curaçao), and the Tax Authorities (Belastingdienst Curaçao).
Regulatory Authorities in Scope
Central Bank of Curaçao and Sint Maarten (CBCS)
CBCS is the supervisory authority for financial institutions, including Virtual Asset Service Providers (VASPs) such as Bitkaya B.V. Its key responsibilities cover licensing and registration of the entity, ongoing prudential and integrity supervision, AML/CFT compliance oversight, and Fit & Proper testing of key persons.
CBCS reporting obligations include:
- Periodic compliance reports (AML/CFT, governance, risk management).
- Annual audited financial statements.
- Notifications of material changes (ownership, management, business model).
- Incident reporting (cybersecurity, fraud, operational failures).
Financial Intelligence Unit (FIU Curaçao)
FIU Curaçao is the national authority for AML/CFT reporting and monitoring of unusual transactions. It enforces the National Ordinance on the Reporting of Unusual Transactions (NORUT) and oversees suspicious/unusual activity monitoring.
FIU reporting obligations include:
- Unusual Transaction Reports (UTRs): Mandatory reporting of all transactions that meet objective or subjective indicators.
- Timely reporting via the FIU online portal.
- Cooperation during investigations.
Communication protocol: Reports filed electronically via the FIU system. Immediate notification of compliance officer for escalations. Maintain strict confidentiality — non-disclosure to customer (tipping-off prohibition).
Tax Authorities (Belastingdienst Curaçao)
Responsible for taxation and enforcement of fiscal obligations, including Corporate Income Tax (CIT) compliance, turnover tax (if applicable), wage tax and social security reporting for employees, and possible VAT/GST considerations depending on transaction types.
Tax reporting obligations include:
- Annual CIT filings (typically due within 5 months after financial year-end).
- Monthly/quarterly turnover tax filings.
- Monthly payroll/wage tax declarations.
Communication protocol: All filings via the online tax portal. Prompt response to tax authority inquiries or audits. Maintain supporting documentation for at least 10 years.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Maintain authority and obligation inventory | Capture for CBCS, FIU, tax and other applicable regulators: role, key responsibilities, reporting obligations, and communication protocol. | Authority and obligation inventory record |
| 2 | Record reporting calendar entries | Record report type, trigger, frequency, deadline, responsible party, channel, template, preparer, reviewer, approver and retention period. Minimum recurring obligations are listed in the table below. | Reporting calendar and change log |
| 3 | Monitor regulatory and business changes | Track new CBCS circulars, FIU reporting requirements, or tax authority guidelines and update the calendar promptly. | Updated calendar entries with change log |
| 4 | Issue reminders before deadlines | Send reminders and confirm contributor availability. | Reminder records and contributor confirmations |
| 5 | Escalate unclear applicability | Escalate unclear applicability or conflicting instructions to Compliance and management. | Escalation records and resolutions |
| 6 | Review calendar completeness | Review quarterly and obtain annual management approval. | Quarterly review notes and annual management approval |
Minimum recurring obligations (step 2):
| Authority | Report Type | Frequency | Responsible Party | Deadline |
|---|---|---|---|---|
| CBCS | Prudential/AML Report | Quarterly | Compliance Officer | 30 days after quarter-end |
| CBCS | Audited Financials | Annually | Finance Dept | 5 months after year-end |
| FIU | Unusual Transactions | Ad hoc | Compliance Officer | Immediately upon detection |
| Tax Authorities | CIT Return | Annually | Finance Dept | 5 months after year-end |
| Tax Authorities | Turnover Tax | Monthly/Quarterly | Finance Dept | 15th of following month |
| Tax Authorities | Wage Tax | Monthly | Finance Dept | 15th of following month |
Records
- Authority and obligation inventory (covering CBCS, FIU, and Tax Authorities with roles, responsibilities, reporting obligations, and communication protocols)
- Reporting calendar and change log (with the six recurring report types above at minimum)
- Responsibility and approval matrix
- Reminders, exceptions and approvals
Relationships
- Policy: POL-REG-001 Regulatory Reporting and Communication Manual
- Process: PRC-RSA-001 Resilience Systems and Assurance
- Control: CTRL-REG-001 Ensure Regulatory Obligations and Calendar Are Current
History
- 2026-07-26: Created from sections 2, 3 and 5 of the approved REG Manual.
- 2026-07-28: Enriched with full authority profiles (CBCS, FIU, Tax Authorities), reporting obligations, communication protocols, and the complete reporting calendar table from PDF sections 2 and 5.