2. FATF Mutual Evaluation
Aruba
FATF Mutual Evaluation
Sator Regulatory Consulting
Helen Hatton - Managing Director
Neil Haworth – Regulatory Consultant

3. FATF Process
Global Standards applied to large and small countries
Scaleable solutions harder for small places – not impossible
Focus is on EFFECTIVENESS
Regulation
Supervision
Enforcement
International Co Operation

4. International Community want evidence that Aruba is ready to stand as a
Responsible partner in the Global Community
A partner – not a pariah
A friend – not a risk

5. Why bother?
Doesn’t Aruba do OK?
Our finance centre is only 1% of our economy – is this a big deal for us? Worth the investment?
FATF standards are written for big countries not ones like ours

6. Imagine ………………
Its Spring 2012, the international recession is over, recovery is all around ……
The FATF issues a world wide public warning that
Aruba does not sufficiently apply the 40+9 recommendations and that countries dealing with Aruba should apply additional due diligence.
Text… A B C D E F G H I J

7. every transaction moving in or out of Aruba
Sator Regulatory Consulting Limited
Text… A B C D E F G H I J
A bad scenario
Automatically all compliant jurisdictions are required under the FATF process to apply heightened due diligence to:-
every transaction moving in or out of Aruba
every customer originating from Aruba including trading companies (import/export of goods)
Stage III
SANCTION

8. Text… A B C D E F G H I J
Local business costs increase, access to markets is reduced
Wealthy residents business affairs are slowed
New investors are less attracted to the island, with associated slowing of building and other trades
Standard & Poors type global credit ratings are degraded resulting in Aruban currency and debt issues becoming harder to place
Stage III
SANCTION

9. Text… A B C D E F G H I J
Aruban based assets or deals are no longer as attractive to investment committees – for example the board of a mutual fund investing in real estate for future hotel or residential development would be less likely to include investment in Aruban property in its asset portfolio
WORST SCENARIO?
OECD countries instruct their subsidiaries to withdraw
US dollar clearing system is closed to Aruban originating transactions
Stage III
SANCTION

10. AML/CFT STRATEGY GROUP
TOUGH DECISIONS:-
Your agency senior management, simply has to be up to the tasks ahead.
They have to be of the personal calibre to do the job AND you have to resource them properly
This does not mean a blank cheque, but it does mean having people in post who are solutions oriented and capable of adapting, changing and leading that change.