Financial & Regulatory Reporting

Fixed-fee engagement

The Annual Determination

A written determination of your reporting position under Aruba’s foreign exchange regime: whether you must file, for which accounts, from when, and what the commission position is on your outgoing payments. Measured against the Afl. 1,500,000 threshold and traced to the decrees actually in force.

What you are buying

A document. One signed written determination of your reporting position, which you own and can hand to your accountant, your auditor, your bank or your board. It answers a question that currently has no answer on your file, and it holds for the year it is measured against.

You are not buying a subscription, a retainer, or representation before the Centrale Bank. You are buying the answer, in a form somebody else can check.

What it is

  • A written, reasoned position on whether you must report
  • The threshold measured, with your figures shown
  • Each conclusion traced to the decree in force
  • Yours to keep, use and show to anyone

What it is not

  • A ruling by the Centrale Bank — it does not bind the regulator
  • Legal advice
  • A filing — no return is submitted as part of this
  • A commitment to engage me for anything further

What you receive

  1. Account inventoryEvery account and exposure outside Aruba identified, dormant ones included.
  2. The threshold test, with the figures shownBalances and gross annual transactions measured separately against the Afl. 1,500,000 line, because either one reaching it puts you inside the obligation.
  3. A written positionReportable or not, for which accounts, effective from which date — with the reasoning set out so your accountant, auditor or board can follow it.
  4. Commission positionHow your outgoing payments should be classified and what that means for what you owe.
  5. Regulatory sourcingEach position traced to the state ordinance and the amending decree in force, including the June 2026 decrees.
  6. Remediation plan, where neededIf periods are outstanding or a notification was missed, what it takes to bring them current and in what order.

What I need from you

  • Statements for every foreign account covering the period under review, in whatever format your bookkeeping already produces.
  • A list of accounts held outside Aruba, including any that are dormant or rarely used.
  • Your latest annual report, which the Centrale Bank requires from entities notifying that they fall below the threshold.
  • Whoever knows the payment patterns — one short conversation, usually enough.

How it runs

Payment confirms the engagement. I send an NDA and a short request list the same day, and nothing else is needed from you until the statements arrive.

From receipt of complete records, the determination is delivered as a signed document. Where a point turns on the Centrale Bank’s own practice rather than the wording of a decree, I take that question to the Bank on procedure — as a general question, with no client named — before giving you a position. That can add time, and you are told when it does.

If the determination finds outstanding periods, bringing them current is separate work, quoted before it starts. Nothing is begun on that basis without your agreement.

The determination is also how I learn your company properly — the accounts, the counterparties, the shape of your payment flows. If you go on to engage me for filing, that work is already done, which is why onboarding afterwards is quick. If you do not, you still own the document and nothing further is owed.

What happens after you have it

A determination ends in one of three places. Each one has a route you can take yourself, and a route where I do it. Both are set out in the document, whichever you choose.

Outcome one

You fall below the threshold

No monthly obligation. But the Bank requires notification by email, with your latest annual report attached, and the test has to be re-run against next year’s figures.

  • Do it yourself: the determination tells you exactly what to send, to whom, and what to keep on file. Most companies can handle this without me.
  • Or engage me: I make the notification, and the annual re-test keeps the position current for AWG 265 a year.
Outcome two

You must report

Monthly filing applies, or — if you move money abroad rarely — per-transaction applications may cost you less. The determination says which, and why.

  • Do it in-house: the document sets out the schedule, the codes that apply to your flows, and what your working papers need to contain.
  • Or engage me: I file monthly as RE Administrator in Vortex.
Outcome three

You have periods outstanding

Returns never filed, or a notification missed. The determination establishes how many periods, from when, and what closing them involves — scoped, so you can decide with a number in front of you.

  • Do it yourself: the remediation plan is written to be followed by someone else.
  • Or engage me: quoted separately before anything starts.
If you engage me, there is no onboarding fee. Setting a new client up normally carries a one-time fee to configure the entity in the reporting system. After a determination that work is already done — I have the accounts, the counterparties and the flows. Engage me within twelve months of delivery and the onboarding fee is waived.
Year two onwards

Annual re-test

For anyone who has had a determination and is not on a filing retainer

instead of AWG 1,000 AWG 265 / year
  • The threshold re-measured against the new year’s balances and gross transactions.
  • Your position updated in writing, or confirmed unchanged.
  • Any rule change applied — if a decree moves the line, you are re-tested against the new one.
  • You hear it from me, not from a letter, in the year you cross back over.
Add the annual re-test

Why so much less: the discovery is already done. Year two is measurement, not investigation. Cancel any time; it never renews without notice.

Terms

What you are agreeing to

Scope

The fee covers one determination for one entity, against one period’s figures, and it does not vary with what the work turns up. Additional entities are AWG 1,000 each. Filing, backlog regularisation and per-transaction applications are separate engagements, always quoted before they begin.

Confidentiality

An NDA is issued on engagement. Your records are held separately from every other client’s, and any question that needs to go to the Centrale Bank goes as a general question of procedure, with no client identified.

Cancellation

Full refund on request at any point before I begin work on your records. Once the determination is under way it is not refundable, because the work is the research. If I conclude I cannot answer your question, you are refunded in full and told why.

Fees after this

Nothing further is owed for the determination. A one-time onboarding fee normally applies when a new entity is set up in the reporting system; engage me for filing within twelve months of your determination and it is waived, because that configuration is done during the determination itself.

The annual re-test

Optional, and only available after a determination. AWG 265 a year re-measures your position against the new year’s figures and any change in the rules. Cancel at any time; it does not renew without notice, and it is not required to keep your determination valid.

What this is not

Financial and compliance advisory, not legal advice, and not a ruling by the Centrale Bank. A determination sets out a reasoned position traced to the operative text; it does not bind the regulator.