CBCS Draws Lessons from Girobank N.V. Case  

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Comprehensive supervisory overhaul implemented since 2021 

WILLEMSTAD/PHILIPSBURG — The Centrale Bank van Curaçao en Sint Maarten (CBCS) is  releasing a Lessons Learned report, following the investigative report on Girobank N.V.  published by Deloitte (Netherlands) on July 21, 2023. Deloitte’s report outlines the findings of  its investigation into the affairs of Girobank from 2013 to 2019. The CBCS has analyzed these  findings, identified valuable lessons, and implemented necessary changes and measures.  

The Lessons Learned report highlights the key insights gained by the CBCS. Notably, in early 2021,  the CBCS fundamentally transformed its supervisory approach, adopting a more focused and  intrusive stance. The aim of this enhanced supervision is to swiftly bring non-compliant  institutions in line with legal standards, thereby minimizing adverse impacts on customers and  society. Additionally, the CBCS has shifted from a reactive to a proactive supervisory approach,  intervening at the first sign of elevated risk rather than waiting for actual violations. To support this  proactive approach, the CBCS is executing a multi-year program to update and tighten the  standards laid down in Curaçao and Sint Maarten’s supervisory framework, elevating it to  international levels. 

In addition to these broader supervisory reforms, the report also includes specific lessons learned  with regard to the sale of Girobank’s shares, ongoing supervision, and interventions and  enforcement. Also mentioned is the need for additional financial crime expertise, including  capabilities for conducting forensic investigations.  

After Deloitte’s investigative report, the CBCS consulted external (criminal law) attorneys for their  opinion on filing additional charges. Based on their advice, which considered previous filings, no  further actions are deemed necessary. The CBCS has adopted this recommendation. 

The full Lessons Learned report is available on the CBCS website at:  https://www.centralbank.cw/publications/notes-analyses/analyses.