Vulnerabilities in the transition from the Netherlands Antillean guilder to the Caribbean

guilder: warning about money laundering and financial (crime) risks

Sint Maarten and Curaçao are undergoing a historic transition: the introduction of the
Caribbean guilder. With this change, the current Netherlands Antillean guilder will be
replaced by the Caribbean guilder. While this development marks a significant milestone for
the financial landscape of Sint Maarten and Curaçao, this transition also brings considerable
financial (crime) risks. The Centrale Bank van Curaçao en Sint Maarten (CBCS and the
Financial Intelligence Unit Sint Maarten (FIU) emphasize the importance of vigilance and
cooperation to prevent misuse during this transition period.
Transition periods from an old currency to a new one can be vulnerable to money laundering
and financial crime. It is important that all service providers under the supervision of CBCS
and FIU are aware of the risks of misuse of this opportunity. Service providers are advised to
further strengthen their AML/CFT/CFP framework. This means closely monitoring clients’
transaction patterns. The introduction of the Caribbean guilder may present certain risks and
challenges, including:

  • Suspicious deposits: depositing cash without a clear source or purpose;
  • Fraud in currency exchange: converting illegally obtained funds in the old currency
    into the new currency, creating the appearance that the old currency was legally
    obtained;
  • Purchasing luxury goods with cash: such as real estate, jewelry, and vehicles;
  • Buying casino chips with illegally obtained old currency and exchanging them for new
    currency after minimal or no play.
    Criminals aim to go unnoticed and remain anonymous. Service providers must therefore be
    on the alert and, considering various money laundering techniques, implement appropriate
    preventive measures tailored to their business operations (products, services, client base,
    distribution channels).
    It is crucial that supervised institutions remain vigilant and report unusual transactions to the
    FIU in a timely manner to protect the integrity of the financial system and ensure a smooth
    transition to the Caribbean guilder.