Sanctions regime

Sanctions regime

For client due diligence as well as reporting purposes, reporting entities are required to consult sanction lists containing individuals, entities and legal persons, which are subject to freezing measures. A distinction is made between the United Nations Security Council Resolutions containing sanctions (UN lists) and the European Union (EU) sanction lists.

Pursuant to Article 2, paragraph 1, section b, of the Regulation Indicators Unusual Transactions, reporting entities are required to report:

  • UN lists: The ISIL (Da’esh) & Al-Qaida Sanction List, and the UN Taliban List (implementation of the Sanctions State Ordinance 2006 (AB 2007 no. 24))
  • Designated lists by the head of FIU: These lists usually concern updates to the national (Aruban) sanction list and EU sanction lists. The FIU designates lists based on several factors, e.g. by applying an AML/CFT risk-based approach, and by considering international developments that (might) directly affect Aruba.

The UN sanctions list and the assinged lists by the head of FIU must be reported under indicator 130102.

Both the UN and the EU sanction lists are accessible through consolidated lists. Below you will find the links to these consolidated lists: