Regulatory expectations for financial institutions continue to increase.
Agreed-Upon Procedures (AUP) engagements related to the Central Bank of Curaçao and Sint Maarten provide structured testing of compliance with anti-money laundering, counter-terrorist financing, and proliferation (AML/CFT/CFP) obligations under the National Ordinance for Trust Service Providers (TSPSQ).
These engagements assess specific regulatory requirements and deliver factual findings on your organization’s compliance practices, without expressing an audit opinion. The outcome is clear insight into how your AML and regulatory controls perform in practice.


Your compliance challenges
AML and regulatory requirements continue to evolve.
Financial institutions and trust service providers must demonstrate effective compliance with obligations related to client due diligence, risk assessments, transaction monitoring, and reporting of unusual transactions. At the same time, supervisory expectations from the Central Bank of Curaçao and Sint Maarten continue to grow.
Organizations often face practical challenges:
How do we demonstrate compliance consistently?
Are our policies, procedures, and documentation inspection-ready?
Where do potential gaps exist within our AML framework?
Preparing for regulatory supervision requires clarity, structure, and defensible processes.
Our AUP Approach
Our Agreed-Upon Procedures engagements are designed to provide transparent and objective insight into your compliance framework.
Using a risk-focused approach aligned with supervisory expectations from Central Bank of Curaçao and Sint Maarten, we perform targeted procedures to test key AML/CFT and TSPSQ requirements.
As part of the global network of Grant Thornton, our teams apply proven methodologies while tailoring procedures to your organization’s regulatory profile and risk exposure.
Throughout the engagement, we maintain clear communication and deliver practical reporting that enables management to address findings efficiently and prepare confidently for supervisory reviews.

Our perspective
Effective compliance is more than meeting regulatory requirements. It is about demonstrating that your organization can manage financial crime risks responsibly.
When AML frameworks are structured, documented, and consistently applied, organizations build credibility with regulators and protect their reputation.
Take the next step
Connect with our Assurance specialists to design Agreed-Upon Procedures that strengthen your AML compliance framework and support regulatory readiness.
