Curaçao raises maximum fine for anti-money laundering violations to one million guilders

WILLEMSTAD--Businesses and professionals subject to Curaçao’s anti-money laundering rules could face significantly heavier financial penalties for failing to comply with requirements governing unusual transactions, with the maximum administrative fine increased from 100,000 guilders to one million guilders.

The change forms part of a broader strengthening of Curaçao’s framework against money laundering, terrorism financing and proliferation financing. The legislation moved the maximum administrative penalty from the fifth category under Curaçao’s Criminal Code, which carries a ceiling of NAf 100,000, to the sixth category, where the maximum is NAf 1 million. Government’s explanatory memorandum said the previous maximum was considered too low and that the increase was intended to make sanctions more effective and deterrent while bringing Curaçao closer to international standards.

The increased penalty does not mean that an individual is automatically fined for carrying out an unusual transaction. The rules apply primarily to financial institutions, businesses and professionals that have legal obligations to identify clients, monitor transactions, maintain required records and report transactions that meet established unusual-transaction indicators to the Financial Intelligence Unit Curaçao, FIU Curaçao.

Under the amended Landsverordening melding ongebruikelijke transacties, the supervisory authority can impose an administrative fine for violations of a range of compliance obligations, including reporting, registration and other requirements imposed on regulated service providers. The maximum amount for each type of violation is determined through implementing legislation, with the overall ceiling now tied to the sixth-category fine.

The framework also gives regulators stronger tools against repeat offenders. If the same offender commits the same violation again within five years after an earlier fine became final, the applicable administrative fine can be doubled. In cases where the financial benefit obtained through the violation exceeds the normal statutory maximum, the regulator may set the penalty at up to twice the value of that benefit. The law also allows a lower fine where an offender can demonstrate that the prescribed amount would be excessive because of exceptional circumstances.

The move represents a significant change from the earlier system. Government documents explaining the reform noted that Curaçao had previously been limited to a maximum administrative fine of NAf 100,000 per violation, compared with much higher ceilings elsewhere in the Kingdom. The explanatory memorandum cited maximums of EUR 900,000 in the Netherlands and Afl. 1 million in Aruba when making the case for tougher sanctions in Curaçao.

The legal changes are part of a wider effort to bring Curaçao’s anti-money laundering regime in line with standards developed by the Financial Action Task Force and to address weaknesses identified through the country’s own risk assessments. The 2024 legislation amended several laws covering client identification, unusual transaction reporting and supervision of financial and non-financial sectors.

Government continued that process in 2026. On May 20, the Council of Ministers approved amendments to the regulations governing administrative penalties and penalty payments under both the 2022 service-provider decree and the 2021 unusual-transactions decree. The amended drafts were subsequently sent to the Governor for signature.

The compliance net has also widened beyond traditional banks and financial institutions. Curaçao’s anti-money laundering legislation covers various non-financial businesses and professions, including real estate professionals, vehicle dealers and rental businesses, jewelers, notaries, attorneys, accountants and tax advisers, depending on the services and transactions involved. Earlier regulations already imposed different fixed penalties depending on the sector and type of violation.

Earlier this year, Curaçao also introduced new reporting thresholds affecting certain businesses. Under Publicatieblad 2026, No. 34, car rental businesses, for example, are required to report qualifying unusual transactions of 20,000 Caribbean guilders or more. The measure is particularly relevant to large cash transactions and forms part of the effort to bring more non-financial sectors into the country’s anti-money laundering monitoring system.

Financial institutions and other regulated service providers are required to report unusual transactions to FIU Curaçao. A transaction being reported as unusual does not itself establish criminal activity. The FIU analyses reports and may provide relevant information to investigative authorities where further examination is warranted.

The latest increase in potential penalties therefore places greater responsibility on businesses and professionals that function as gatekeepers to the financial system. Failure to meet reporting and compliance requirements can now carry consequences substantially greater than under Curaçao’s previous enforcement structure.

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