Purpose
Ensure failed CDD and relationship termination feed the FIU reporting decision when suspicion is present.
Normative
Bitkaya shall assess failed CDD and CDD-driven termination for ML/TF suspicion and, where the statutory reporting condition is met, report to FIU Curaçao with the reasons CDD failed or the relationship was terminated.
Descriptive
This requirement supplements the general unusual-transaction reporting process and does not treat every failed CDD case as automatically reportable.
Source reference: LID Article 2d.
Assurance Assertions
- Failed CDD cases are escalated to Compliance or the MLRO.
- The reporting decision and rationale are documented.
- Required FIU reports include the failed-CDD or termination reasons.
Relationships
- Source: SRC-LID-001 Landsverordening identificatie bij dienstverlening
- Procedure: PROC-AML-005 Perform FIU Reporting and Case Escalation
- Control: CTRL-AML-005 Ensure FIU Reporting and Case Escalation Are Completed
Assurance
- Source verified: yes
- Implementation linked: yes
- Wording unambiguous: review
History
- 2026-07-26: Created from LID Article 2d.