Purpose
Ensure reportable completed and proposed transactions reach FIU Curaçao without delay.
Normative
Bitkaya shall identify completed or proposed unusual transactions using the applicable indicators, escalate them immediately to authorized Compliance personnel and submit the required report to FIU Curaçao without delay through the prescribed reporting channel.
Descriptive
The reporting obligation is triggered by an unusual transaction as defined through the Article 10 indicators. It applies to both completed and proposed transactions and can be activated by knowledge obtained in the course of servicing a client, including passive knowledge.
Source references: MOT Articles 1(d), 10 and 11(1); P.B. 2024, no. 60.
Assurance Assertions
- Monitoring and staff escalation channels cover completed and proposed transactions.
- FIU submission timestamps demonstrate reporting without delay.
- Decisions not to report are documented with the applicable indicator analysis.
Relationships
- Source: SRC-MOT-001 Landsverordening melding ongebruikelijke transacties
- Procedure: PROC-AML-004 Perform Transaction Monitoring and Alert Review
- 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 MOT Articles 1, 10 and 11.