Purpose
Coordinate regulatory submission after the AML framework determines FIU, sanctions or related supervisory reporting is required. This procedure implements the FIU Curaçao reporting obligations (section 2.2), the Compliance Officer’s role as primary liaison for AML/CFT/CPF-related regulatory communication (section 3.1), the escalation framework distinguishing separate categories of action (section 4.3), the recordkeeping requirements for AML/CFT/CPF and sanctions matters (section 4.4), and the sanctions-hits handling requirements (section 7.4) of the approved Regulatory Reporting & Communication Manual.
FIU Curaçao Reporting Context
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.
Reporting Obligations:
- 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).
Compliance Officer Role
The Compliance Officer acts as the primary liaison for AML/CFT/CPF-related regulatory communication and is responsible for coordinating internal case handling, UTR reporting, sanctions escalation, and any applicable supervisory reporting or notification to the CBCS arising from material sanctions, compliance, or financial crime matters. The Compliance Officer also ensures that reporting decisions, internal classifications, supporting rationale, and communications with relevant authorities are properly documented and retained.
Escalation Framework (Section 4.3)
Regulatory escalation must distinguish between different categories of action. Where relevant, Bitkaya shall separately consider and document:
- internal escalation and management visibility;
- external FIU reporting obligations;
- CBCS supervisory reporting or notification obligations; and
- operational restrictive measures, including blocking, freezing, or holding transactions or relationships where legally required.
Sanctions-related matters, unusual transactions, and significant compliance incidents must be assessed across these separate dimensions rather than treated as a single generic event type.
Recordkeeping for AML/CFT/CPF and Sanctions Matters (Section 4.4)
All regulatory communications, filings, decisions, drafts, supporting evidence, escalation records, and follow-up actions must be retained in a secure and retrievable manner. For AML/CFT/CPF and sanctions matters, the record must include, where applicable:
- the alert or trigger;
- internal classification;
- review notes and rationale;
- the basis for false-positive closure, where relevant;
- the status and outcome of escalation;
- any restrictive measures taken;
- UTR filing details, where applicable; and
- any CBCS notification or reporting record, where applicable.
Sanctions Hits (Section 7.4)
Not all sanctions or financial crime matters should be treated solely as generic breach events. Confirmed sanctions matches may create immediate legal obligations relating to restrictive measures, asset blocking or freezing, FIU reporting, and CBCS notification or reporting. These obligations must be considered separately and documented clearly.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Receive AML framework output | Receive the documented internal classification and authorized reporting decision from the AML framework. | Internal classification and reporting decision record |
| 2 | Preserve confidentiality | Prevent tipping off — maintain strict non-disclosure to customer per the tipping-off prohibition. | Confidentiality attestation or access controls |
| 3 | Distinguish and assess separately | Separately assess UTR reporting, sanctions restrictive measures, FIU sanctions reporting, and CBCS notification, treating each as a separate dimension rather than a single generic event type. | Per-dimension assessment notes |
| 4 | Verify mandatory data | Verify mandatory data, transaction reconstruction, rationale and supporting evidence. | Verification checklist and supporting evidence |
| 5 | Submit via FIU portal | Submit through the FIU portal electronically without delay and retain the receipt and report reference. | FIU portal receipt and report reference |
| 6 | Track FIU interactions | Track FIU questions, information requests or suspension orders and cooperate during investigations. | FIU correspondence and cooperation log |
| 7 | Record restrictive measures | Record restrictive measures (blocking, freezing, or holding transactions or relationships) and any CBCS communication separately. | Restrictive measures and CBCS communication records |
| 8 | Retain case record | Retain the case and reporting record under restricted access, including: the alert or trigger, internal classification, review notes and rationale, basis for false-positive closure (where relevant), status and outcome of escalation, restrictive measures taken, UTR filing details (where applicable), and any CBCS notification or reporting record (where applicable). | Restricted-access case file with all required fields |
Exceptions and Escalation
This procedure does not replace AML investigation or decisioning. A missing CBCS or restrictive-action assessment shall be escalated even when the FIU report is complete.
Relationships
- Policy: POL-REG-001 Regulatory Reporting and Communication Manual
- Process: PRC-RSA-001 Resilience Systems and Assurance
- Control: CTRL-REG-003 Ensure FIU and Sanctions Reporting Is Complete and Confidential
History
- 2026-07-26: Created from sections 2.2, 3.1, 4.3, 4.4 and 7.4 of the approved REG Manual.
- 2026-07-28: Enriched with full FIU Curaçao authority profile, Compliance Officer role, escalation framework, AML/CFT/CPF recordkeeping fields, and sanctions-hits handling from PDF sections 2.2, 3.1, 4.3, 4.4, and 7.4.