Filing an FIU report
Under Curaçao’s National Ordinance on the Reporting of Unusual Transactions (NORUT), service providers must report unusual transactions to the Financial Intelligence Unit (FIU) Curaçao. The FIU accepts these reports through its goAML portal, either typed in by hand or as an XML file in the goAML format.
BECCO Trust generates that XML for you, filled with the client’s company details and every person and company in the structure. You describe the transaction, download the XML and upload it to the FIU portal.
Before you can report
Section titled “Before you can report”Two things must be in place before the first report:
- Platform FIU information. A platform administrator fills in the FIU information section of the platform settings: the legal name, the FIU transaction code and the address of your organization as the reporting entity, and enables FIU sharing. This information identifies your organization in every generated report.
- A goAML account. Uploading reports requires your organization to be registered with the FIU Curaçao’s goAML portal. See the FIU registration page or contact the FIU at goaml@fiucuracao.cw.
When to file a report
Section titled “When to file a report”A report is filed per transaction, based on one of the FIU’s indicators:
| Indicator code | Meaning |
|---|---|
| R0000111 | A transaction which is reported to the police or judicial authorities in connection with money laundering or the financing or terrorism. |
| R0000114 | An intended transaction carried out by or for the benefit of a person, legal person, group or entity that is mentioned on a list compiled in pursuance of the Sanctions National Ordinance. |
| R0000211 | A transaction giving cause to assume that it may be connected with money laundering or terrorist financing. |
Generate the report XML
Section titled “Generate the report XML”-
Open the client’s Information tab and press Export data.
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Choose Export as FIU format.
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Fill in the report details:
- Transaction date: the date the unusual transaction took place (or was intended).
- FIU indicator code: pick one of the three indicators above; the full description is shown below the field.
- Explanation: describe in as much detail as possible the reason for reporting the unusual transaction.
- What action was taken because of the transaction?: describe the current status regarding the transaction, for example whether it was blocked, refunded or executed.
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Press Export as FIU format.
The dashboard builds the goAML XML and confirms with upload instructions (see below). The report includes, automatically:
- Your organization as the reporting entity, from the platform’s FIU information.
- The client company and every person and company in the structure, with their details: names, addresses, dates of birth, passports, nationalities and their relationship to the client (for example “Beneficial Owner of X with 30% ownership”).
- A unique report reference, built from your platform’s FIU transaction code and the date, with a counter that runs per day.
A copy of the XML is stored with the client file, and the export is recorded in the audit trail as an FIU report.
Upload the report to the FIU portal
Section titled “Upload the report to the FIU portal”The dashboard does not send anything to the FIU itself; the upload happens in the FIU’s own portal. The confirmation screen lists the steps:
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Download the FIU report XML.
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Open the FIU Curaçao reporting portal (goAML) via the link in the dialog and sign in with your organization’s goAML account.
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Navigate to New reports → XML Upload.
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Upload the XML file and press Upload report file. Nothing needs to be added in the Uploaded attachments area.
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Verify the report under Submitted reports → XML Reports. The report has now been filed with the FIU Curaçao.