Financial & Regulatory Reporting Get a determination

Questions & answers

The things people ask before they commit

Two of these take a while to answer properly, so they come first. The rest are short.

The obligation

Why do I have to report at all?

Aruba runs a fixed exchange rate and a managed foreign exchange system. Moving money across that boundary is, in principle, something you ask for rather than simply do. The reason it rarely feels that way is that, for companies which report, reporting substitutes for asking.

What the Bank takes in exchange is information: classified, period by period. So paying the commission is not the whole of it — the statistical input is the consideration.

The alternative, if you would rather

Apply to the Centrale Bank for each transaction, individually, before it is made. Slow, tedious, and it puts a regulator inside the timing of your ordinary payments. Nobody chooses it — but it is what you fall back towards if the reporting stops.

Your company registered in Aruba Accounts held abroad any bank outside Aruba, dormant ones included Payments leaving Aruba suppliers, lenders, affiliates abroad EVERY MONTH EVERY PAYMENT FALA report balances and transactions, filed Foreign Exchange Commission driven by classification CBA supervisor INDEPENDENT IN RETURN: GENERAL PERMISSION TO TRANSACT — NO LICENCE, PAYMENT BY PAYMENT the freedom to move money is granted against the data, not bought with the commission
Two obligations, assessed separately — relief from one does not touch the other. Both feed the same return, which is why classification is the crux: a transaction code is not an administrative label but a statement of what the payment actually was — a purchase, a dividend, a loan drawdown, a capital contribution. Code it wrong and the commission can still be right while the report tells the Bank something untrue.

If you are behind

I have not reported in years. What now?

Most companies that come to me are not current. They opened an account abroad years ago, nobody mentioned a reporting obligation, and the longer it went unaddressed the harder it became to raise. That is not evasion. It is how this almost always happens.

The instinct is to wait, because the cost of coming forward is immediate and the cost of being found is vague. That instinct is backwards: waiting adds a period every month and spends the one thing working in your favour — that you raised it yourself.

Bring me a backlog of any length. I have yet to meet one that could not be brought current in an orderly way.

Before you commit to anything

  • Scoped first. You find out how many periods are outstanding and what closing them takes, before deciding anything.
  • Nothing leaves without your say-so. NDA signed first, and any question that goes to the Bank goes as a general question of procedure, with no name attached.
  • Then it is ordinary work. Periods reconstructed, classified, filed in sequence, with the explanation prepared rather than improvised.
You raise it scoped privately, under NDA A letter arrives the gap is found for you THE SAME WORK, EITHER WAY Reconstruct each period Classify the transactions File in sequence Current, on your terms your timetable, and the explanation ready first Current, on theirs a deadline you did not set, and a weaker footing
The remedial work does not get smaller by waiting — it gets larger by one period a month, and the choice of footing expires the moment the letter is sent.

Shorter answers

Everything else

What actually triggers the obligation?

Holding a bank account outside Aruba, and sending payments out of the local system. The first drives FALA reporting on balances and transactions; the second drives the Foreign Exchange Commission, charged according to how each payment is classified. They are separate regimes, assessed separately — relief from one does not touch the other.

What is the Afl. 1,500,000 threshold?

A line the Centrale Bank introduced in June 2026. Reporting is mandatory where balances or annual transactions reach Afl. 1,500,000 — which means you are only outside it if both are below. Gross movement is what catches people: every payment in and every payment out counts, and they do not net off. The full note is here.

Will I be fined?

That is the Bank's decision, not mine, and anyone who promises you an outcome there is overselling. What is on the public record is that where the CBA identifies non-compliance it weighs measures ranging from an informal conversation through a written warning to formal action, and that the seriousness of the case forms part of that judgement. A company arriving with complete records and a plan is not in the same position as one whose gap is discovered for it.

Can I just start reporting now and leave the past alone?

No, and it is usually the worse option. Starting fresh draws attention to the periods behind it without resolving them. Bringing them current in sequence, with the explanation prepared, is both cleaner and — in my experience — a shorter conversation.

What does a determination cost?

AWG 1,000 per entity, all taxes included, and it does not change with what the work turns up. Shareholder contributions, institutional loans, a parent settling obligations abroad — these surface during the determination, not before it. Full detail here.

Do I have to hire you afterwards?

No. The determination is a document you own, and it is written so that someone else can act on it — including you. Where the answer is that you fall below the threshold, most companies can make the notification themselves, and the determination tells you exactly what to send and to whom. If you do engage me within twelve months, the onboarding fee is waived, because the set-up work is already done.

What happens to my data?

An NDA is signed before anything moves. Records are held per client and never visible across engagements, encrypted at rest and backed up, and retained for as long as statutory record-keeping requires before being destroyed. Where a question has to go to the Centrale Bank to scope work, it goes as a general question of procedure with no client named.

Is this legal advice?

No. It is financial and compliance advisory. A determination sets out a reasoned position traced to the state ordinance and the decree actually in force; it does not bind the regulator and it is not a ruling by the Centrale Bank. Where a question is genuinely unsettled, my advice says so rather than guessing.

Question not here? Ask it. Most take one short conversation, and I will tell you if it is something I cannot help with.