Update to Aruba’s Interim National Decree on Priority Sanctions Regimes: Zimbabwe No Longer Subject to Targeted Financial Sanctions
FIU-Aruba wishes to inform all reporting entities that the National Decree amending the Interim National Decree on Priority Sanctions Regimes (Landsbesluit tot wijziging van het Interim-landsbesluit prioritaire sanctieregimes, AB 2026 no. 14) entered into force on 26 June 2026. The amendment updates Aruba’s Interim National Decree on Priority Sanctions Regimes (Interim-landsbesluit prioritaire sanctieregimes, AB 2019 no. 47) by removing Zimbabwe from the list of priority sanctions regimes.
This amendment reflects Council Regulation (EU) 2026/384 of 17 February 2026, which amended the European Union’s restrictive measures concerning Zimbabwe. Consequently, Zimbabwe has been removed from Annex I and Annex II of Aruba’s Interim National Decree on Priority Sanctions Regimes.
What does this mean for reporting entities?
As a result of this amendment, Zimbabwe and the natural persons, legal persons and entities previously designated under this sanctions regime are no longer subject to targeted financial sanctions (bevriezingsmaatregelen).
Therefore, transactions that were previously reported under objective indicator 130102 because they were subject to targeted financial sanctions should no longer be reported under that indicator.
Risk-Based Approach Continues to Apply
The removal of targeted financial sanctions only affects the reporting obligation under objective indicator 130102.
Reporting entities must continue to assess transactions using a risk-based approach. Where a transaction gives reason to suspect money laundering, terrorist financing, proliferation financing or any of the predicate offences, it must be reported to FIU-Aruba under the applicable subjective reporting indicator.
Where a transaction does not give rise to reporting under the subjective reporting indicator, reporting entities should continue to assess whether any other objective reporting indicators are applicable.
The relevant documents can be accessed below:
- National Decree amending the Interim National Decree on Priority Sanctions Regimes (Landsbesluit tot wijziging van het Interim-landsbesluit prioritaire sanctieregimes, AB 2026 no. 14)
- Explanatory Memorandum to the National Decree amending the Interim National Decree on Priority Sanctions Regimes (Nota van Toelichting behorende bij het Landsbesluit tot wijziging van het Interim-landsbesluit prioritaire sanctieregimes, AB 2026 no. 14)
- Council Regulation (EU) 2026/384 of 17 February 2026 amending Council Regulation (EC) No 314/2004 concerning restrictive measures in view of the situation in Zimbabwe
