Compliance

At NewLeaf Notary, we are committed to acting with integrity and in full compliance with the law.

Under the National Ordinance on the Notary Profession and the National Ordinance to Combat Money Laundering and the Financing of Terrorism, notaries in Aruba are legally required to verify the identity of clients and investigate the source of their funds and wealth in certain transactions — such as those involving real estate or corporate matters.

These rules exist to help prevent money laundering, fraud, and the financing of terrorism, and to maintain transparency in all financial and legal dealings.

Client Due Diligence

The notary’s duty to investigate each client — known as Client Due Diligence (CDD) — varies depending on the level of risk.
Several factors determine how extensive this investigation should be, including:

  • Whether the client is a foreign national;
  • Whether the client works in an industry with higher money-laundering risks;
  • Whether the client, the transaction, or the funds involved are linked to a high-risk country;
  • Whether the client has been mentioned in the media in connection with possible financial misconduct;
  • Whether the requested notarial service is consistent with the client’s profile or business activities;
  • Whether the client holds or has held a prominent political position (which may increase corruption risk).

In other words, the extent of the notary’s investigation depends on the situation.
If there are higher risks or unusual circumstances, the notary is legally required to conduct a more detailed inquiry.

What the Notary Must Verify

According to the National Ordinance to Combat Money Laundering and the Financing of Terrorism, the notary must verify and document the following information:

  • The identity of the client (and of any authorized representative);
  • The purpose and background of the transaction or service requested;
  • Whether the representative is legally authorized to act on behalf of the client;
  • Whether the client is acting on their own behalf or on behalf of another party;
  • For financial transactions: the source of the funds being used;
  • For companies and other legal entities: the ownership and control structure, including the Ultimate Beneficial Owners (UBOs);
  • Whether the client or UBO is a Politically Exposed Person (PEP).

Identification of Natural Persons

To verify identity, the notary requires an official, valid identification document:

  • Aruban nationals can be identified with a valid ID card or driver’s license (both must include a passport photo).
  • Foreign nationals must present a valid national passport.

These documents allow the notary to confirm that each client is who they claim to be, as part of the legal requirements designed to protect both the client and the integrity of the transaction.

Identity and Ultimate Beneficial Owners (UBOs) of Legal Entities

When the client is a legal entity, such as a company or limited liability company (LLC), the notary must verify the entity’s identity.
This is usually done by obtaining an extract from the Chamber of Commerce trade register, either in physical form or electronically, directly requested by the notary.

In addition to identifying the company itself, the notary must also know who ultimately owns or controls the business.
These individuals are called Ultimate Beneficial Owners (UBOs).

Every legal entity has at least one UBO, but it may have several.
A UBO is always a natural person — someone who ultimately benefits from or controls the company.

If no clear UBO can be identified, or if there is any doubt about who the UBO really is, the notary is required to treat all members of the company’s senior management (for example, all statutory directors of an LLC) as “pseudo-UBOs.”

This process ensures full transparency and helps prevent the misuse of legal entities for money laundering or other illegal activities.

Origin of Funds

The notary is also required to verify the source of the funds used in any financial transaction.
This applies even if the money comes from an Aruban bank account.

While banks have their own compliance checks, the notary has an independent duty to investigate where the funds come from and to ensure that they are legitimate.

This requirement also applies when:

  • Payments do not go through the notary’s third-party account (for example, if the buyer pays the seller directly); or
  • The transaction is financed in another way, such as by offsetting debts, barter, or in-kind contributions.

By conducting this verification, the notary ensures that the transaction complies with the law and that all funds used originate from legal and transparent sources.