CBCS draws lessons from Girobank N.V. case

July 9, 2024  –WILLEMSTAD, PHILIPSBURG – The Centrale Bank van Curaçao en Sint Maarten (CBCS) is releasing a Lessons Learned report, following the investigative report on Girobank N.V. published by Deloitte (Netherlands) on July 21, 2023. Deloitte’s report outlines the findings of its investigation into the affairs of Girobank from 2013 to 2019. The CBCS has analyzed these findings, identified valuable lessons, and implemented necessary changes and measures.  

The Lessons Learned report highlights the key insights gained by the CBCS. Notably, in early 2021, the CBCS fundamentally transformed its supervisory approach, adopting a more focused and intrusive stance. The aim of this enhanced supervision is to swiftly bring non-compliant institutions in line with legal standards, thereby minimizing adverse impacts on customers and society. Additionally, the CBCS has shifted from a reactive to a proactive supervisory approach, intervening at the first sign of elevated risk rather than waiting for actual violations. To support this proactive approach, the CBCS is executing a multi-year program to update and tighten the standards laid down in Curaçao and Sint Maarten’s supervisory framework, elevating it to international levels.  

In addition to these broader supervisory reforms, the report also includes specific lessons learned with regard to the sale of Girobank’s shares, ongoing supervision, and interventions and enforcement. Also mentioned is the need for additional financial crime expertise, including capabilities for conducting forensic investigations.  

After Deloitte’s investigative report, the CBCS consulted external (criminal law) attorneys for their opinion on filing additional charges. Based on their advice, which considered previous filings, no further actions are deemed necessary. The CBCS has adopted this recommendation.

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