Fixed-fee engagement
The Annual Determination
A written determination of your reporting position under Aruba’s foreign exchange regime: whether you must file, for which accounts, from when, and what the commission position is on your outgoing payments. Measured against the Afl. 1,500,000 threshold and traced to the decrees actually in force.
What you are buying
A document. One signed written determination of your reporting position, which you own and can hand to your accountant, your auditor, your bank or your board. It answers a question that currently has no answer on your file, and it holds for the year it is measured against.
You are not buying a subscription, a retainer, or representation before the Centrale Bank. You are buying the answer, in a form somebody else can check.
What it is
- A written, reasoned position on whether you must report
- The threshold measured, with your figures shown
- Each conclusion traced to the decree in force
- Yours to keep, use and show to anyone
What it is not
- A ruling by the Centrale Bank — it does not bind the regulator
- Legal advice
- A filing — no return is submitted as part of this
- A commitment to engage me for anything further
What you receive
- Account inventoryEvery account and exposure outside Aruba identified, dormant ones included.
- The threshold test, with the figures shownBalances and gross annual transactions measured separately against the Afl. 1,500,000 line, because either one reaching it puts you inside the obligation.
- A written positionReportable or not, for which accounts, effective from which date — with the reasoning set out so your accountant, auditor or board can follow it.
- Commission positionHow your outgoing payments should be classified and what that means for what you owe.
- Regulatory sourcingEach position traced to the state ordinance and the amending decree in force, including the June 2026 decrees.
- Remediation plan, where neededIf periods are outstanding or a notification was missed, what it takes to bring them current and in what order.
What I need from you
- Statements for every foreign account covering the period under review, in whatever format your bookkeeping already produces.
- A list of accounts held outside Aruba, including any that are dormant or rarely used.
- Your latest annual report, which the Centrale Bank requires from entities notifying that they fall below the threshold.
- Whoever knows the payment patterns — one short conversation, usually enough.
How it runs
Payment confirms the engagement. I send an NDA and a short request list the same day, and nothing else is needed from you until the statements arrive.
From receipt of complete records, the determination is delivered as a signed document. Where a point turns on the Centrale Bank’s own practice rather than the wording of a decree, I take that question to the Bank on procedure — as a general question, with no client named — before giving you a position. That can add time, and you are told when it does.
If the determination finds outstanding periods, bringing them current is separate work, quoted before it starts. Nothing is begun on that basis without your agreement.
The determination is also how I learn your company properly — the accounts, the counterparties, the shape of your payment flows. If you go on to engage me for filing, that work is already done, which is why onboarding afterwards is quick. If you do not, you still own the document and nothing further is owed.
What happens after you have it
A determination ends in one of three places. Each one has a route you can take yourself, and a route where I do it. Both are set out in the document, whichever you choose.
You fall below the threshold
No monthly obligation. But the Bank requires notification by email, with your latest annual report attached, and the test has to be re-run against next year’s figures.
- Do it yourself: the determination tells you exactly what to send, to whom, and what to keep on file. Most companies can handle this without me.
- Or engage me: I make the notification, and the annual re-test keeps the position current for AWG 265 a year.
You must report
Monthly filing applies, or — if you move money abroad rarely — per-transaction applications may cost you less. The determination says which, and why.
- Do it in-house: the document sets out the schedule, the codes that apply to your flows, and what your working papers need to contain.
- Or engage me: I file monthly as RE Administrator in Vortex.
You have periods outstanding
Returns never filed, or a notification missed. The determination establishes how many periods, from when, and what closing them involves — scoped, so you can decide with a number in front of you.
- Do it yourself: the remediation plan is written to be followed by someone else.
- Or engage me: quoted separately before anything starts.
Annual re-test
For anyone who has had a determination and is not on a filing retainer
- The threshold re-measured against the new year’s balances and gross transactions.
- Your position updated in writing, or confirmed unchanged.
- Any rule change applied — if a decree moves the line, you are re-tested against the new one.
- You hear it from me, not from a letter, in the year you cross back over.
Why so much less: the discovery is already done. Year two is measurement, not investigation. Cancel any time; it never renews without notice.
Once the position is settled
Work for whichever position you are in
Not every engagement is a monthly retainer. Companies that already report often want review or a blockage cleared rather than the whole function handed over; companies that transact rarely are better off applying than reporting. I work all three ways.
Monthly FALA reporting
Balances and transactions compiled, reconciled against statements and submitted through Vortex. I act as RE Administrator, so the portal is my problem, not yours.
Vortex · monthly
Rejected submissions, unblocked
A form that will not go through, a validation error nobody can place, a period that refuses to close. If you already report and the cycle keeps stalling, this is usually a short job with an immediate result.
Troubleshooting · per incident
Review, without handing over the work
For teams that file their own returns and want a second pair of eyes: classification checked, balances tied out, working papers reviewed before submission. You keep the function; I keep it accurate.
Second-line · monthly or periodic
Per-transaction applications
If you move money abroad rarely, monthly reporting may be more machinery than the situation warrants. I prepare and submit the individual applications instead, and tell you plainly which route costs you less.
Low-frequency · per application
Outflow classification
The code says what the payment actually was, and that is the substance the Bank is asking for — not just the basis of the commission. I classify the full ledger and document why each call was made.
5455 / 5555 / full code set
Non-routine transactions
Shareholder contributions, institutional loans, intercompany settlement by a foreign parent. The entries that do not fit the standard template are the ones that draw questions.
Capital · debt · intercompany
Quarterly payment overview
A standing check that commission payments are current and nothing has quietly fallen behind. Arrears are cheaper to find in March than in an inquiry letter.
Every quarter
Inquiries and variance explanations
When the Centrale Bank comes back with a question, I answer it — from working papers built when the filing was made, not reconstructed under pressure afterwards.
Correspondence · follow-up
Whichever position you are in, it starts the same way: a written determination of where you actually stand.
Beyond the filing
Have a situation that does not fit the form?
Not every exposure is a monthly report. Groups restructure, parents settle obligations centrally, a subsidiary opens in a jurisdiction nobody has read the rules for yet. Those questions get a scoped, fixed-fee investigation before anyone talks about a retainer — so you know what an answer costs before you commit to finding one.
- Exemption and threshold analysisPositions traced to the operative decree, with the Centrale Bank consulted on procedure where it matters.
- Cross-border and regional scopingWhat a new jurisdiction requires of an Aruban group, mapped before the first payment moves.
- Financial reporting and analysisManagement reporting, variance analysis and the reconciliations behind them, for finance teams that are short-handed rather than short of ideas.
- Reporting automationTurning a manual monthly compile into a pipeline, built around the formats and systems you already run.
Terms
What you are agreeing to
Scope
The fee covers one determination for one entity, against one period’s figures, and it does not vary with what the work turns up. Additional entities are AWG 1,000 each. Filing, backlog regularisation and per-transaction applications are separate engagements, always quoted before they begin.
Confidentiality
An NDA is issued on engagement. Your records are held separately from every other client’s, and any question that needs to go to the Centrale Bank goes as a general question of procedure, with no client identified.
Cancellation
Full refund on request at any point before I begin work on your records. Once the determination is under way it is not refundable, because the work is the research. If I conclude I cannot answer your question, you are refunded in full and told why.
Fees after this
Nothing further is owed for the determination. A one-time onboarding fee normally applies when a new entity is set up in the reporting system; engage me for filing within twelve months of your determination and it is waived, because that configuration is done during the determination itself.
The annual re-test
Optional, and only available after a determination. AWG 265 a year re-measures your position against the new year’s figures and any change in the rules. Cancel at any time; it does not renew without notice, and it is not required to keep your determination valid.
What this is not
Financial and compliance advisory, not legal advice, and not a ruling by the Centrale Bank. A determination sets out a reasoned position traced to the operative text; it does not bind the regulator.