Anti-money laundering rules for businesses

The anti-money laundering act WMTF (S.B. 2022 no. 138, tightened in August 2024 by S.B. 2024 no. 99) does not only apply to banks. Notaries, lawyers, accountants, real estate agents, car dealers, gold dealers, casinos and exchange offices are also "service providers" and must register with FIU Suriname within three months, know their customers, keep records for seven years and report unusual transactions. The supervisor can impose fines of up to SRD 1,000,000.

On this page (16)

• The law: the WMTF and the 2024 amendment
• Does my business fall under it?
• Duty 1: register with FIU Suriname
• Duty 2: risk policy and compliance function
• Duty 3: customer due diligence and UBO
• Duty 4: record keeping
• Duty 5: reporting unusual transactions
• Sanctions and terrorist financing
• Supervision, fines and objections
• NRA 2.0: where the risks are
• Suriname and the CFATF
• A compliance programme for a small business
• Checklist
• What if...
• Sources
• Frequently asked questions

The law: the WMTF and the 2024 amendment

The Money Laundering and Terrorist Financing Prevention Act (WMTF) dates from 19 November 2022. It replaced the Unusual Transactions Reporting Act and the Identification Act for Service Providers, which had applied since 2002. Money laundering itself is a crime under the Penal Code and the Money Laundering Criminalisation Act; the WMTF covers prevention: what businesses must do to avoid being misused.

After criticism in the CFATF's first follow-up report, the WMTF was amended in August 2024 (S.B. 2024 no. 99). According to the FIU Suriname guideline of July 2025 the main changes are:

• dealers in heavy equipment and vessels and aircraft now fall under the reporting duty, alongside motor vehicle dealers;
• customer due diligence is required for a one-off (occasional) transaction of USD 15,000 or more, or the equivalent in another currency;
• service providers must take enhanced risk measures for higher risks.

In the same month the International Sanctions Act was also amended (S.B. 2024 no. 100); see below.

Does my business fall under it?

You are a service provider if you provide one of the services in article 1 of the WMTF to a client, professionally or commercially, in or from Suriname. The FIU groups reporting entities into categories. The thresholds below come from the FIU guideline of July 2025.

Who	When	Supervisor	Objective reporting threshold
Notaries, lawyers, accountants, administration offices, tax advisers (cat. E)	When advising or assisting on buying and selling real estate, managing money or accounts, setting up or managing companies, buying businesses, providing a registered or correspondence address, or acting as nominee shareholder. Accountants also when setting up and auditing accounts	FIU Suriname	USD 25,000
Real estate agents and dealers (cat. E)	Trading in or brokering the purchase and sale of real estate	FIU Suriname	USD 25,000
Dealers in gold, precious metals and precious stones (cat. F)	Professional or commercial trading, including jewellers that trade in gold	FIU Suriname	USD 5,000
Dealers in motor vehicles, heavy equipment, vessels and aircraft (cat. G)	Cars, buses, trucks, tractors, excavators, mopeds, motorcycles, boats and aircraft	FIU Suriname	USD 25,000
Gaming operators (cat. H)	Casinos, lotteries and other games of chance	Gaming Control Institute (Toezicht en Controle Instituut Kansspelen)	USD 10,000
Exchange offices (cat. C)	Buying and selling SRD and foreign currency	Central Bank of Suriname	SRD 5,000
Money transfer offices (cat. D)	Domestic and international transfers	Central Bank of Suriname	USD 2,000
Banks, credit and investment institutions; life insurers (cat. A and B)	Financial services under article 1(c)	Central Bank of Suriname	USD 10,000 (banks), USD 25,000 (life insurers)
Virtual asset service providers	Exchanging, transferring or holding crypto and similar assets	Central Bank of Suriname	Only allowed under conditions still to be set by law

The second National Risk Assessment (NRA 2.0) mentions different thresholds for some sectors. We follow the more recent guideline of the supervisor itself (FIU, July 2025). If in doubt, ask the FIU in writing.

Note

• Art and antiques: anyone who professionally trades in or brokers the sale of works of art and antiques also falls under article 1 of the WMTF. Ask the FIU which category to register under.
• Lawyers and notaries: determining a client's legal position, representation in court and advice on bringing or avoiding proceedings are excluded (article 1(2)).
• Ordinary shops without these activities do not fall under the WMTF, but their bank will still ask questions. See Opening a business bank account and Accepting payments.
• Gold sector: licences and export rules apply beyond the WMTF. See Gold and oil price and Mining and gold.

Duty 1: register with FIU Suriname

Every service provider registers with FIU Suriname within three months of starting business and at the same time appoints a compliance officer (article 28). This is done with the registration form on the FIU's site or a form requested from the FIU. The legal representative or an authorised person submits:

• a certified extract from the KKF trade register;
• a copy of valid ID of the representative or authorised person;
• proof of authority to represent or of the authorisation;
• the details of the compliance officer.

After registration there is an information meeting, and the compliance officer gets access to REPSYS, the FIU's reporting portal. A new or replacement compliance officer is reported separately. At the end of 2024, 50 financial and 272 non-financial service providers were registered: 169 notaries, real estate agents, accountants, administration offices and lawyers, 32 gold dealers, 53 car dealers and 18 gaming operators.

The compliance function must suit the nature and size of your business and work independently and effectively; in a small business it can be simple. According to the FIU it may also be outsourced to an external party.

Duty 2: risk policy and compliance function

• Risk assessment (article 3): periodically identify the risks of your customers, products, services, transactions, channels and countries. Use the findings of the national risk assessment. Document it and provide it to your supervisor on request.
• New products or technology: assess the risk before you introduce them, for example crypto payments or online customer onboarding.
• Policies and procedures (article 4): proportionate to the size of your business, approved by senior management, and reviewed regularly.
• Compliance function (article 5): independent and effective, responsible for the compliance programme.
• Group: if you belong to a group, apply the group policy insofar as it meets the WMTF (article 6).

Duty 3: customer due diligence and UBO

When

You carry out customer due diligence (CDD) in any case (article 7(3)):

• when starting a business relationship;
• for a one-off transaction of USD 15,000 or more, or the equivalent, also when it is paid in linked parts;
• for a one-off foreign electronic transfer of USD 1,000 or EUR 1,000 or more;
• when there are signs of money laundering or terrorist financing;
• when you doubt previously obtained information, or the risk of an existing customer calls for it.

What

1. Identify and verify the customer. Individuals: name, address, date of birth, nationality, and type, number, date and place of issue of the document. Verify with a valid driving licence, ID card or passport (article 10). Legal entities: a certified KKF extract or a notarial deed showing legal form, names, directors, address and representatives (article 11).
2. Identify the UBO. The ultimate beneficial owner is the natural person who owns or controls the customer, or on whose behalf the transaction is made. For a company, map the ownership and control structure.
3. Establish the purpose and nature of the relationship or transaction.
4. Check the representative: is the person in front of you authorised, and is the customer acting for themselves or for someone else?
5. Monitor on an ongoing basis whether transactions match what you know about the customer, investigating the source of funds where needed.

If you cannot complete due diligence, you may not start the relationship or carry out the transaction (article 9). A notary may verify identity at the moment identification is required.

Simplified and enhanced

• Simplified (article 13): only where the risk is demonstrably low, for example the Surinamese government or a state-owned NV. Skipping it is never allowed.
• Enhanced (article 14) is required for: customers not resident or established in Suriname, customers not physically present, private wealth management, personal asset-holding vehicles, companies with bearer shares or shares held for someone else, customers from countries with weak AML rules, politically exposed persons, correspondent banking relationships and non-profit organisations that receive or pass on money. You then ask for more information, the source of funds and wealth, senior management approval, and you monitor more often. You may require the first payment to come from an account in the customer's name at a bank with equivalent standards.
• Politically exposed persons (article 16): including family members and close associates. Senior management approval, source of wealth and ongoing enhanced monitoring.
• Enhanced due diligence must not lead to these customers being excluded automatically (article 14(4)).

You may rely on due diligence by another service provider that is itself subject to comparable rules and supervision, but final responsibility stays with you (article 12).

Duty 4: record keeping

• Keep copies of IDs and due diligence documents, account information, business correspondence and your analyses for at least seven years after the service ends or after the transaction (articles 19 and 21).
• Record per transaction what the law requires (article 20). A car dealer records a description of the vehicle and the amount; a gold dealer a description of the metal and the amount; a notary, for a real estate transfer, the description, location and amount.
• Keep records so that every transaction can be reconstructed, and longer if a competent authority asks.
• Keep files up to date; the customer must report changes in identity or UBO details straight away.
• Privacy (article 22): use these data only for AML purposes, inform the customer beforehand about the processing, and destroy the data after the retention period.

Duty 5: reporting unusual transactions

If in your work you find facts that may point to money laundering or terrorist financing, you report the completed or intended transaction without delay to FIU Suriname (article 29). There are two kinds of report:

Kind	When	Deadline
Objective	The transaction, or a series of linked transactions, reaches your sector's threshold	Within 14 days at most
Subjective	You have a reasonable suspicion of money laundering, an underlying crime or terrorist financing, whatever the amount	Immediately once it is clear the indicator applies

Reports are filed digitally through REPSYS, in the FIU's Excel reporting format. A report contains, among other things, the identity of the customer and UBO, the ID document, the type, date, time and place of the transaction, amount and currency, origin and destination of the funds, the indicator, and for a subjective report a description of the situation: which facts and circumstances support your suspicion. You do not need to prove the suspicion.

Signals from the FIU guideline

• The customer asks many questions about your reporting duty or wants to know how to avoid a report.
• Amounts are split to stay under a threshold or avoid identification.
• The explanation for the transaction keeps changing, or the customer knows little about its purpose.
• The customer acts under someone else's direction, or says they act for someone else.
• Payments come from or go to parties with no visible link to the customer.
• The income or occupation does not match the amounts.

Examples from NRA 2.0 of what led to reports: changes in the board of foundations, mortgages being set up, sales of plots, transfers of real estate for a symbolic amount, and transactions of local politically exposed persons. In 2024 the FIU received a total of 348,413 unusual transaction reports.

Secrecy and protection

• No tipping off: you may not tell the customer that you reported (articles 45 and 46). Doing so risks up to ten years in prison and a sixth-category fine (article 47). If your due diligence would alert the customer, you may stop it, but you must still report (article 8(3)).
• Protection: reporting in good faith makes you not liable for third-party damage (article 37) and does not breach confidentiality duties (article 36). Your report cannot be used as evidence against you for money laundering (article 34).
• The FIU may request additional information, which you must provide within the deadline it sets (article 31).

Sanctions and terrorist financing

Alongside the WMTF, the International Sanctions Act applies, last amended in August 2024 (S.B. 2024 no. 100). The International Sanctions Council (Raad Internationale Sancties, RIS), whose members include the Central Bank, the FIU and the Public Prosecution Service, keeps the national sanctions list, publishes sanctions decisions on its website and can issue guidelines to all service providers.

• Service providers must follow sanctions decisions and guidelines of the Council and their supervisor without delay and strictly. According to the explanatory notes, without delay ideally means within a few hours, so that assets cannot disappear.
• Screen new and existing customers and UBOs against the UN sanctions lists and the national list. If you get a hit, apply the freeze in the sanctions decision and contact your supervisor straight away.
• Supervision lies with the same supervisors as under the WMTF. Non-compliance can lead to penalty payments of up to SRD 1,000,000 a day; repeated non-compliance within two years is punishable by detention of up to one year or a fine, and breaching the prohibition in article 9 of that act by up to six years in prison.
• NRA 2.0 rates the terrorist financing risk in Suriname as medium high, higher than in the first NRA, mainly because of the informal economy and links between organised crime and regional networks.

If you work with non-profit organisations (foundations, churches, charities) that receive or pass on money, enhanced due diligence applies: check the statutory purposes, who is responsible and where the money comes from (article 18 WMTF).

Supervision, fines and objections

The supervisor (article 38) works on a risk basis: higher-risk sectors are checked more often. The FIU carries out off-site inspections (questionnaires and documents) and on-site inspections at the business. The supervisor may request any information, inspect and copy books and documents, and impose measures (article 39). You must cooperate.

Measure	What	Legal basis
Instruction	Order to follow a specific course of action within a reasonable time; can also target directors	Article 38(4) WMTF
Administrative fine	Up to SRD 1,000,000, for not complying with guidelines or an instruction	Article 38(5) WMTF
Penalty payment	Up to SRD 100,000 a day if you do not carry out measures after an inspection	Article 40 WMTF
Tipping off	Up to ten years in prison and a sixth-category fine	Article 47 WMTF
Sanctions rules	Penalty payment up to SRD 1,000,000 a day; criminal law for repeat breaches	International Sanctions Act (S.B. 2024 no. 100)

Objection: you object to a supervisor's decision in writing, with reasons, within 30 days. The supervisor decides within 15 days; no decision counts as a rejection. You can then go to the cantonal court within 60 days (articles 41 to 43). The power to impose a fine lapses three years after the breach (article 44).

NRA 2.0: where the risks are

The second National Risk Assessment (NRA 2.0) covers 2021 to 2023, with legislation up to July 2024. The main points:

• Suriname's overall vulnerability to money laundering remains high.
• The number of predicate offences with a high threat rose from three to six: drug trafficking, corruption, illegal gold activities, tax evasion, illegal logging and timber trade, and smuggling.
• Main gap in the rules: identifying and verifying the beneficial owners of legal persons.
• Real estate, car dealers and dealers in precious metals got a higher risk rating than in the first NRA, mainly because of a lack of basic AML knowledge in those sectors.

Relative risk per non-financial sector according to NRA 2.0:

Sector	Total vulnerability	Risk NRA 2.0	Risk NRA 1.0
Dealers in precious metals and stones	High	High	Medium high
Real estate	High	Medium high	Medium
Car dealers	Medium high	Medium high	Medium
Casinos	High	Medium high	Medium high
Lawyers	Medium	Medium	Medium
Accountants	Medium	Medium low	Medium
Notaries	Medium	Medium low	Medium

Your risk assessment must take these findings into account (article 3(2) WMTF). If you are in a higher-risk sector, expect more frequent inspections and stricter questions from your bank.

Suriname and the CFATF

Suriname has been a member of the Caribbean Financial Action Task Force (CFATF), the FATF's regional body, since 1998. In the Mutual Evaluation Report of January 2023 Suriname scored, on the 40 technical Recommendations, 1 compliant, 9 largely compliant, 23 partially compliant and 7 non-compliant, and low on all effectiveness outcomes. As a result Suriname is in the enhanced follow-up process.

• After follow-up reports in October 2023, October 2024 and 2025 the score stands at 10 compliant, 17 largely compliant, 7 partially compliant and 6 non-compliant.
• Effectiveness (whether the rules work in practice) has not yet been reassessed; that is the biggest challenge.
• The next follow-up report is due in November 2026.
• FIU Suriname joined the Egmont Group, the international network of FIUs, on 5 June 2024.

Why this matters to you: NRA 2.0 warns that insufficient progress may threaten access to correspondent banks and increases the chance of being placed on the FATF "grey list". That affects every importer and exporter through more expensive and slower foreign payments. Good compliance by businesses themselves counts in the assessment.

A compliance programme for a small business

You do not have to be a bank to get it right. For a car dealer, real estate office, jeweller or administration office with a handful of staff, the following is often enough:

1. Register with the FIU and appoint a compliance officer, with a deputy.
2. Write a risk assessment of two to five pages: who your customers are, which products and payment methods, which countries, what the NRA says about your sector, and which situations you treat as high risk.
3. Write a procedure of one to three pages: when you do due diligence, which documents you collect, when you apply enhanced measures, who approves high-risk customers, how you screen against sanctions lists, how and by whom reports are made.
4. Make a customer form with ID details, UBO, purpose of the transaction and source of funds, and a checklist per file.
5. Limit cash: have large amounts paid through the bank, preferably from an account in the customer's name. That strengthens your file. See Accepting payments.
6. Train your staff yearly on red flags and the ban on tipping off, and record the training.
7. Review yourself every year: sample files, missed reports, up-to-date customer data. Update the policy and have management sign it.
8. Archive everything for seven years, digitally and securely.

An accountant or compliance adviser can help; see Business resources and Government offices and contacts. Company law UBO questions also relate to the new Book 2 of the Civil Code: see New Civil Code.

Checklist

• Established whether my activities fall under article 1 WMTF, and in which category
• Registered with FIU Suriname within three months, compliance officer appointed and REPSYS access
• Written risk assessment, taking NRA 2.0 into account
• Procedures approved by management
• Customer files with valid ID, KKF extract or deed, UBO and purpose
• Enhanced due diligence for non-residents, PEPs, complex structures and non-profit organisations
• Screening against the UN and national sanctions lists at onboarding and when the lists change
• My sector's threshold known; objective reports within 14 days, suspicions immediately
• Staff trained on red flags and secrecy
• Seven-year archive, in order and searchable
• Yearly review scheduled

What if...

• ...I never registered? Do it now, with your KKF extract and ID, and appoint a compliance officer. Waiting for an inspection makes a fine more likely.
• ...a customer wants to pay cash above the threshold? You may carry out the transaction once due diligence is complete; you report it within 14 days as an objective report. Ask about the source of the money and record it.
• ...a customer refuses to show ID? Then you may not carry out the transaction (article 9). Consider a report if the refusal is suspicious.
• ...I am unsure whether something is suspicious? Record your reasoning. With a reasonable suspicion you report; you do not need to prove it, and a good-faith report is protected.
• ...the FIU or police request information? Provide it within the deadline. It does not breach professional secrecy (article 31(3)).
• ...my bank closes my account? See Opening a business bank account. A solid compliance file of your own helps with a new bank.
• ...I disagree with a fine? Object to the supervisor within 30 days and, if needed, go to the cantonal court within 60 days. See also Debt collection and disputes.

Sources

• WMTF, S.B. 2022 no. 138 (FIU Suriname)
• FIU Suriname: reporting guideline (July 2025)
• FIU Suriname: annual report 2024
• FIU Suriname: registration, reporting forms and legislation
• Second National Risk Assessment (NRA 2.0), public version
• Amendment to the International Sanctions Act, S.B. 2024 no. 100
• FATF/CFATF: Suriname follow-up report 2025
• FATF/CFATF: Mutual Evaluation Report Suriname (January 2023)
• Central Bank of Suriname: NRA 2.0 publication

Checked on 26 October 2026. General information, not legal advice. Thresholds and guidelines may change; check the current position with your supervisor.