Reporting Obligation | FIU-Aruba | Financial Intelligence Unit

Article 1 of the AML/CFT State Ordinance distinguishes the following service providers that are required to report unusual transactions to the FIU (the list below is not exhaustive).

Accountants
Lawyers and legal advisers
Administration offices
Banks
Tax advisers
Investment institutions
Casinos and Internet casinos
Factoring companies
Money transfer companies
Dealers in goods of great value
Collection agencies
Life insurers or brokers
Estate agents
Notaries
Pawnshops
Trust offices

As a reporting entity, you are (also) obliged to report unusual transactions if you perform one or more of the services listed below (article 1, section 1 of the AML/CFT State Ordinance).

Financial service providers

Anyone commercially conducting one or more of the activities or operations listed below to or for the benefit of a client.

to accept deposits and other repayable funds from the public
to grant loans
financial leasing, with the exception of consumer-related leasing
to transfer or enable the transfer of money or monetary values
to issue and manage means of payment other than money, at any rate including credit cards, debit cards, checks, traveler’s checks, bank and money orders, and electronic money
to provide financial guarantees and commitments
to trade in money market instruments, foreign currencies, payment instruments, shares, interest and index instruments, transferable securities, and commodities futures trading
to participate in the issue of securities and to provide financial services related to this issue
to manage individual and collective investment portfolios
to receive for safekeeping and manage cash or liquid securities on behalf of third parties
to otherwise invest, administer or manage funds or monies on behalf of third parties
to underwrite, redeem and pay, as well as to act as an intermediary, in the underwriting, redeeming, and payment of life insurance agreements as meant in Article 1 of the State Ordinance Supervision Insurance Business (AB 2000 no. 82), and other investment-related insurance products
to exchange money and foreign currency

Designated non-financial service providers

a natural person, legal person, corporation, or partnership that acts as a lawyer, civil-law notary, tax adviser, or in the exercise of a similar legal profession or company
a natural person, legal person, corporation, or partnership that acts as an external registered accountant, an external accountant-administration consultant, or a similar profession
a natural person, legal person, or corporation which on a commercial or professional basis trades on or acts as an intermediary in the purchase and sale of real estate, vehicles, ships, aircraft, objects of art, antiquity, and the rights to which these objects can be subjected
a natural person, legal person, or corporation trading in precious metals, precious stones, and jewels on a commercial or professional basis
a casino as meant in Article 1, first paragraph, of the State Ordinance Games of Hazard (AB 1990 no. GT 44), as well as an internet casino
a trust and company service provider as meant in Article 1 of the State Ordinance Supervision Trust and Company Service Providers (AB 2009 no. 13)