Purpose
Ensure sanctions matches are reported to FIU Curaçao in addition to any required restrictive measure.
Normative
Where a client’s identity matches a listed person, legal person, group or entity under the applicable sanctions framework, Bitkaya shall report the match and, where applicable, the resulting frozen funds or transaction to FIU Curaçao without delay.
Descriptive
The VASP objective indicators also classify transactions contrary to applicable sanctions rules as unusual. Reporting does not replace freezing, rejection, blocking or other action required by sanctions law.
Source references: MOT Article 11(1), as amended by P.B. 2024, no. 41; P.B. 2024, no. 60, Annex O(I)(B).
Assurance Assertions
- Sanctions alerts are routed to both restrictive-measures handling and FIU reporting assessment.
- Reports identify any funds or transactions frozen as a result of the match.
- Case records preserve the match evidence, decision and submission timestamp.
Relationships
- Source: SRC-MOT-001 Landsverordening melding ongebruikelijke transacties
- Procedure: PROC-AML-003 Perform Sanctions Screening and Restrictive Measures Escalation
- Procedure: PROC-AML-005 Perform FIU Reporting and Case Escalation
- Control: CTRL-AML-003 Ensure Sanctions Screening and Restrictive Measures Operate
- 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 amended MOT Article 11 and VASP indicator Annex O.