Sint Maarten — Country Risk Report

Sint Maarten (Offshore / IFC • Dutch Caribbean). Risk report as of the 19 Jun 2026 FATF plenary.

Very high country risk, with AML/CFT effectiveness gaps. Sint Maarten's country risk score is 7.8/10, placing it in the very high-risk band. Some information is unavailable, so the available parts are rebalanced and the country will not be labelled Low risk while information is missing. The principal score driver is AML/CFT effectiveness, contributing 6.5 of 7.8 points. Separately, the treatment overlays show that Sint Maarten is not currently FATF grey- or black-listed, and that Sint Maarten is not subject to comprehensive country-wide sanctions and has no direct country-level programme identified. Firms should apply additional scrutiny where exposure involves state-linked entities, restricted sectors, sensitive technology, dual-use goods or politically exposed counterparties.

Recommended treatment

Enhanced due diligence on every relationship, with senior approval and enhanced ongoing monitoring.

At a glance

• FATF status: Not currently listed (one indicator only; it does not set the overall country risk rating by itself)
• No direct country-level sanctions programme identified; sanctions remain a legal treatment overlay and applicable lists must still be screened.
• Governance and institutions: information unavailable
• Corruption (CPI): no score
• Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 7.8/10 (Very high)

Higher score means higher country risk (global average 5.5). Some information unavailable. Provisional composite score. Limited supporting evidence. Enforcement activity and CPI are context only; FATF listing and sanctions are regulatory overlays except the labelled FATF listing status used where no mutual evaluation exists.

Some underlying pillars are unavailable. Available weights are rebalanced; missing evidence is not treated as low risk. Some underlying evidence is unavailable; the available pillars are reweighted transparently and the result should not be treated as equally certain as a composite score. Weight sensitivity 7.5–8.0/10.

How this score was calculated

• AML/CFT effectiveness: 9.4/10 — 69% of this score
• Technical compliance: 4.2/10 — 31% of this score
• Governance and institutions: information unavailable — 0% of this score
• World Bank governance data is incomplete

Sanctions treatment: No direct programme identified. FATF treatment: none.

Principal risk drivers

• AML/CFT effectiveness: 9.4/10 × 69% = 6.5 points
• Technical compliance: 4.2/10 × 31% = 1.3 points

Mitigating factors

• Not currently on the FATF grey or black list.
• No comprehensive country-wide sanctions programme.
• Risk is concentrated in specific counterparties, sectors and transactions rather than applying uniformly.

Business impact

• Customer onboarding (Enhanced): Verify ultimate beneficial ownership and control from more than one source.
• Payments and transactions (Enhanced): Review transaction purpose, counterparties and the full payment routing.
• Trade and export activity (Enhanced): Screen goods, end users and potential dual-use exposure.
• Corporate clients (Review): Assess state ownership, government links and political exposure.
• Ongoing monitoring (Enhanced): Alert on ownership changes, new designations and status changes.

Recommended controls

• Verify ultimate beneficial ownership using more than one reliable source.
• Identify state ownership, government influence and politically exposed persons.
• Screen entities, directors and beneficial owners against applicable sanctions lists.
• Apply enhanced review to technology, defence, telecommunications, financial services and dual-use activity.
• Document transaction purpose and source of funds where cross-border structures are complex.
• Escalate unresolved ownership opacity or adverse information to Compliance.

Enhanced due diligence triggers

• State ownership / control
• PEP involvement
• Sensitive / restricted sectors
• Opaque ownership
• Adverse media
• Dual-use goods & technology
• High-risk intermediary routing

FATF status: Not currently listed

Sint Maarten is not on the FATF grey or black list as of the 19 Jun 2026 plenary.

Source details

International sanctions by issuing body

• UN: No
• EU: No
• UK: No
• US: No

No means the complete UN, UK, EU and US review found no direct country-level programme. People or organisations may still appear on sanctions lists.

Government effectiveness and rule of law (World Bank 2024, percentile)

• Government Effectiveness: no data
• Regulatory Quality: no data
• Rule of Law: no data

Regulators and legal framework

FATF network

FATF network via CFATF.

• Caribbean Financial Action Task Force

Last mutual evaluation: 2025 · report

National regulators

Regulator profiles not yet available on RegActions.

FIU: Egmont Group member (MOT-SM)

Framework signals

• FATF listing: Not currently listed
• International sanctions: no direct country programme identified (legal treatment overlay remains applicable)
• Corruption (CPI): no score
• Rule of law (WGI): no data

Regulatory ecosystem and enforcement visibility

This evidence map is separate from Country Risk v3. It describes official mandates, publication access and RegActions coverage; it does not judge regulatory strength or add points to country risk.

Transparency Index: not scored · Evidence disposition: local-authority-evidence · Mapped official authorities: 2.

Evidence level: Level 1: Identity confirmed. The ladder uses the authority evidenceLevel schema directly and does not infer a level from a URL, site access or RegActions feed count.

1. 1. Identity confirmed — The authority and its mandate are evidenced by official directory provenance.
2. 2. Regulatory activity visible — A qualified authority-owned route has provisional dated activity in the first-page scan.
3. 3. Enforcement visible — A qualified authority-owned enforcement route has provisional dated activity in the first-page scan.
4. 4. Score eligible — Shown only when the authority evidence schema explicitly records score-eligible; no authority currently does.

Enforcement visibility: No authority is classified enforcement-visible or score-eligible in the authority evidence schema. Enforcement visibility remains unknown or limited to identity/activity evidence; this is not evidence of no enforcement.

Authorities and mandate evidence

• Centrale Bank van Curacao en sint Maarten — Level 1: Identity confirmed · Official site challenge-protected

  Mandates: Insurance · Access status: Official site challenge-protected · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: unknown · Latest observed month: unknown.

  Source access was limited during this research check, so activity remains unknown. This is not evidence of inactivity.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  No publication candidate is qualified. Regulatory activity and enforcement visibility remain unknown.

  Activity and enforcement visibility remain unknown; this access limitation does not establish that the authority has no enforcement activity.

• Reporting Center for Unusual Transactions (MOT Sint Maarten) — Level 1: Identity confirmed · Official site reachable

  Mandates: Financial intelligence · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: 0 · Latest observed month: unknown.

  No qualified authority-owned dated route supports an activity signal. This is not evidence of inactivity; blocked, external-context, low-frequency and unvalidated sources remain unknown.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  Publication candidates and qualification

  • Unqualified publication candidate: UN and EU Sanctions

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: not-observable · Source scope: not-observable · Qualification: transport-follow-up-required · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

  • Unqualified publication candidate: IMPORTANT NOTICE DNFBP

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

Download regulatory ecosystem PDF · CSV · JSON

Sector exposure

• Banking & payments (Review): Governance pillar unavailable; no low-exposure conclusion
• Trade & export controls (Low): No direct sanctions or FATF call-for-action overlay identified
• Crypto & virtual assets (Elevated): Effectiveness pillar risk is 9.4/10
• Real estate & luxury assets (High): Beneficial-ownership subscore is 8.2/10
• State-linked & procurement (High): Effectiveness pillar risk is 9.4/10

Derived from sanctions tier, FATF listing, World Bank WGI governance and CPI; no per-sector dataset is asserted.

Sint Maarten: analysis

Sint Maarten is a self-governing constituent country within the Kingdom of the Netherlands, occupying the southern part of the island of Saint Martin, and a Caribbean tourism and financial-services centre. World Bank WGI governance domain data are not published for Sint Maarten, so its headline scoring rests on a limited evidence base; the data gap is not itself a positive or negative assessment. No CPI data or governance percentile are available. The jurisdiction is assessed for AML/CFT purposes by the Caribbean Financial Action Task Force (CFATF); its fourth-round mutual evaluation report was published in the 2025 cycle. No FATF listing or sanctions escalators apply. In the absence of quantified governance data, firms should treat Sint Maarten's risk as evidence-limited and rely on regulatory guidance and third-party country risk assessments.

Outlook

Sint Maarten's forward risk picture rests on its completed CFATF fourth-round mutual evaluation and the associated follow-up process, given the limited governance evidence base. The effectiveness of AML/CFT supervision across its financial and corporate-services sectors, beneficial ownership transparency, and post-disaster institutional reconstruction are the primary monitoring considerations. Any future WGI data availability would allow a modelled risk picture to be constructed.

Key watchpoints

• CFATF fourth-round mutual evaluation follow-up reporting and any technical compliance re-ratings for Sint Maarten.
• Beneficial ownership transparency and source-of-wealth diligence for Sint Maarten corporate structures.
• Effectiveness of AML/CFT supervision across the financial and corporate-services sectors.
• Absence of WGI, CPI and percentile data makes independent risk calibration difficult; supplement with regulatory guidance and third-party assessments.

Assessment currency

• FATF status: Not listed (as of 19 Jun 2026)
• Sanctions exposure: None identified (as of Jul 2026)
• Governance (WGI): Latest dataset incorporated (as of 2024)
• Corruption (CPI): Not available (as of 2025)
• RegActions assessment: Reviewed (as of 19 Jun 2026)

Public evidence layer

FATF action: none. No FATF call-for-action or increased-monitoring status was identified at the latest plenary. This does not establish low risk.

Contextual signals (not scored)

• FATF network membership: FATF regional network: CFATF (present, as of 2026-07)
• EU non-cooperative tax jurisdictions: Not listed in Annex I (absent, as of 2026-02-17)
• Egmont Group FIU: MOT-SM (present, as of 2026-07-17)
• Beneficial-ownership register: No live register identified in the source (unavailable, as of 2026-08-23)
• Transparency International CPI: No CPI result available (unavailable, as of 2025)

Evidence freshness

• FATF monitored-jurisdiction status: current; data 2026-06-19
• FATF mutual evaluation and follow-up ratings: current; data 2026-08-24; follow-up 2025-07; base assessment 2025-07
• World Bank governance indicators: current; data 2024
• UN, UK, EU and US sanctions regimes: current; data 2026-08-30

Contextual signals are public evidence only and do not change the current country-risk score.

Download evidence PDF · CSV · JSON

Contextual risk evidence (not scored)

These eight evidence families provide context only. They do not change the v3.1 headline score. Unavailable means no reviewed, country-comparable evidence is currently ingested; it does not mean the risk is absent.

• Organised crime: Not available. No reviewed country-level organised-crime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Fraud and cybercrime: Not available. No reviewed country-level fraud or cybercrime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Terrorism and proliferation financing: Not available. No reviewed country-comparable terrorism/proliferation threat dataset is currently checked in; FATF listing status remains a separate overlay. Candidate sources are research leads only; they have not been ingested as evidence.
• Trafficking: Not available. No reviewed country-level trafficking dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Financial secrecy and offshore exposure: Not available. No reviewed, licence-clean financial-secrecy index is currently checked in; jurisdiction type alone is not used as a proxy. Candidate sources are research leads only; they have not been ingested as evidence.
• Tax cooperation: Not listed in EU Annex I. Annex I is a political/legal tax-cooperation list, not a general AML, corruption, or country-risk score. Source
• Political stability and conflict: Not available. WGI is an institutional perception indicator, not a conflict event feed or a prediction of future violence. Candidate sources are research leads only; they have not been ingested as evidence.
• Beneficial ownership: Not available. The Open Ownership map is a live-register snapshot and absence means no register was identified in that snapshot, not that no register exists. Candidate sources are research leads only; they have not been ingested as evidence.

Regional peer scores

• British Virgin Islands: 6.8/10 (High)
• Curaçao: 6.3/10 (High)
• Turks and Caicos Islands: 6.2/10 (High)
• Barbados: 5.5/10 (High)
• Gibraltar: 5.5/10 (High)
• Isle of Man: 5.4/10 (High)

Source: FATF black & grey lists · World Bank WGI (CC BY 4.0 — World Bank WGI) · TI CPI (CC BY-ND 4.0 — Transparency International, display only)