Objective
Ensure all applicable reports and notifications have current deadlines and accountable owners across the three key regulatory authorities: the Central Bank of Curaçao and Sint Maarten (CBCS), the Financial Intelligence Unit (FIU Curaçao), and the Tax Authorities (Belastingdienst Curaçao).
Control Activity
Compliance reviews the obligation inventory and reporting calendar quarterly and after regulatory or business change. The obligation inventory must capture, for each authority, its role, key responsibilities, reporting obligations, and communication protocol:
CBCS: Supervisory authority for VASPs. Reporting obligations include periodic compliance reports (AML/CFT, governance, risk management) quarterly, annual audited financial statements, notifications of material changes (ownership, management, business model), and incident reporting (cybersecurity, fraud, operational failures).
FIU Curaçao: National authority for AML/CFT reporting under NORUT. Reporting obligations include Unusual Transaction Reports (UTRs) for all transactions meeting objective or subjective indicators, filed via the FIU online portal immediately upon detection. Maintain strict confidentiality (tipping-off prohibition).
Tax Authorities: Fiscal obligations including Corporate Income Tax (CIT) annually (due within 5 months after financial year-end), turnover tax monthly/quarterly (due 15th of following month), and wage tax monthly (due 15th of following month). All filings via the online tax portal. Maintain supporting documentation for at least 10 years.
The reporting calendar must reflect, at minimum, the six recurring report types:
| 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 |
Evidence
- Expected evidence: Obligation inventory and reporting calendar
- Expected evidence: Responsibility and approval matrix
- Expected evidence: Change review and reminders
- Evidence location: source evidence in SYS-ECM-002 Compliance Reporting and Evidence Repository; target Hermes assessment record in Odoo under ISS-HERMES-001.
- Retention: according to the applicable approved policy and Bitkaya record-retention requirements.
- Testing method: reconcile applicable authorities and requirements to calendar entries and sample deadlines for ownership
- Testing frequency: quarterly
Assurance
Runtime effectiveness results are maintained in Odoo and assessed through the Hermes workflow tracked in ISS-HERMES-001. This note defines design, ownership, evidence expectations and testing method; it does not contain a manually maintained operation, evidence or overall effectiveness rating.
- Design status: implemented
History
- 2026-07-26: Normalized evidence metadata and separated design status from runtime effectiveness.