Aligned with FIU Curaçao and CBCS supervisory expectations
Curaçao’s AML framework places clear responsibilities on both financial institutions and designated non-financial businesses and professions (DNFBPs). Compliance is no longer a checklist exercise, it requires documented judgment, risk-based controls, and the ability to demonstrate alignment during supervisory review.
FamotaX. supports clients in designing and maintaining AML compliance frameworks that are consistent with applicable Curaçao legislation, FIU reporting obligations, and CBCS supervisory standards, with a focus on proportionality, governance, and evidentiary strength.
Our Approach
We work from the principle that AML compliance must be operationally embedded, legally defensible, and commercially workable. Our role is advisory: translating statutory obligations and supervisory expectations into clear internal structures, decision rules, and documentation—without assuming management responsibility or replacing internal compliance functions.
Our services are structured around:
- Supervisory preparedness and internal accountability
- Risk-based AML governance
- Client due diligence and ongoing monitoring frameworks
- Unusual transaction escalation and reporting readiness
- Sanctions and PEP risk alignment
Financial Institutions
For institutions under CBCS supervision
We advise banks, insurers, investment firms, money service providers, and other regulated financial institutions on strengthening AML frameworks in line with CBCS expectations and FIU reporting standards.
Our support focuses on:
- Alignment of AML policies with statutory obligations and supervisory guidance
- Risk-based client onboarding, classification, and monitoring structures
- PEP and sanctions screening governance, including escalation protocols
- Internal control design and second-line compliance structuring
- Preparation for supervisory reviews, thematic inspections, and remediation planning
Our work is designed to support institutions in demonstrating effective control, management oversight, and documented decision-making, rather than merely formal compliance.
DNFBPs
For designated non-financial businesses and professions
DNFBPs operate under increasing regulatory scrutiny, often without the internal compliance infrastructure typical of financial institutions. We support DNFBPs in implementing AML frameworks that are proportionate, understandable, and fit for purpose, while remaining compliant with Curaçao’s AML legislation and FIU expectations.
We advise DNFBPs, including professional service providers, trust-related service providers, real estate-related businesses, and other designated sectors, on:
- Practical application of client identification and verification obligations
- Risk-based transaction monitoring and documentation standards
- Recognition and escalation of unusual transactions
- FIU reporting readiness and internal record-keeping discipline
- Governance arrangements that reflect the size and risk profile of the business
The emphasis is on clarity of responsibility, defensible judgment, and operational feasibility.
Regulatory Alignment
Our AML advisory work is grounded in the applicable Curaçao legal framework, including:
- Client identification and due diligence obligations
- Unusual transaction reporting requirements to FIU Curaçao
- Sanctions compliance and screening expectations
- Enhanced measures for higher-risk relationships, including PEPs
- Supervisory enforcement and administrative sanction exposure
We do not act as a reporting entity, supervisor, or regulator. Our role is to help clients understand, structure, and evidence their own compliance responsibilities.
When FamotaX. Is a Fit
FamotaX. works best with organizations that:
- Take AML obligations seriously at board or senior management level
- Need structure, clarity, and judgment—not templates
- Operate in higher-risk environments or under increased scrutiny
- Want compliance that supports continuity, not disruption