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The Ethics of the "Revolving Door": Why Former Tax Inspectors Must Be Restricted.

By Terence Jandroep, CRA, CQA, CLA Certified Risk Auditor & Forensic Integrity Specialist

terrencejagroep30032026In the specialized field of Forensic Integrity Auditing (FIA) and preemptive risk analysis, we often identify vulnerabilities within systems that are not merely technical, but behavioral. One of the most corrosive structural risks to fiscal integrity emerged in the late 1980s and has since solidified into a systemic crisis: the transition of government tax inspectors into private independent consultancy.

To protect the sanctity of the public treasury and the objectivity of the audit process, we must address this "revolving door" not as a career move, but as a fundamental breach of state security.

The Genesis of Insider Advantage (Post-1980s)
Since the late 1980s, the complexity of global tax codes and the digitalization of audit trails created a premium on "inside knowledge." During this era, a pattern emerged where high-level officials began migrating to the private sector, selling the very blueprints they helped draft.

As a Certified Risk Auditor, I view this through the lens of Information Asymmetry. When a former inspector enters the private sector, they are not just providing legal advice; they are providing a map of the government's internal "blind spots."

A Case of Government Spionage
The term "consultancy" often acts as a polite veneer for what is effectively Government espionage. When a former official leverages their tenure for private gain, they engage in several high-risk activities:

  • Systemic Mapping: They possess intimate knowledge of the "Risk Selection" algorithms used by tax authorities. This allows clients to structure transactions that intentionally bypass the triggers for a formal audit.
  • Protocol Extraction: They carry confidential administrative benchmarks and internal "settlement ranges" that were never intended for public or commercial dissemination.
  • The "Shadow" Influence: By maintaining social and professional ties with active inspectors, these consultants can exert psychological pressure or gain unauthorized intelligence on the progress of ongoing fiscal litigation.

 The Risk to Audit Integrity
From a forensic perspective, the presence of a former insider on the "defense" side of a tax dispute compromises the Forensic Integrity Audit (FIA).

  1. Technical Manipulation: They understand the specific software vulnerabilities and data-entry shortcuts used by government staff, allowing them to "sanitize" records in a way that an external auditor might miss.
  2. Erosion of Public Trust: When the public perceives that a tax inspector is simply "auditioning" for a lucrative private role while still on the state payroll, the moral authority of the tax office evaporates.
  3. Conflict of Interest: There is an inherent risk that active inspectors may be less rigorous when auditing a firm represented by their former supervisor or colleague, fearing future professional repercussions or hoping for a similar "exit" path.

The Professional Mandate: A Call for a Permanent Ban

In the interest of ISO 9001 standards and the principles of preemptive risk containment, the solution is clear. We must implement a mandatory ban or, at minimum, a stringent ten-year "cooling-off" period for former inspectors.

The fiscal frontier cannot be defended if the guards are allowed to sell the keys to the gate. To restore integrity to our regional financial systems from Aruba to Sint Maarten we must recognize that the tools of the state belong to the public, not to the highest bidder in the private consultancy market. It is time to treat the "revolving door" as the National security threat it truly is.


Prime Minister Dr. Luc Mercelina Expresses Condolences on the Passing of Former President of Suriname, Chandrikapersad Santokhi.

mercelinasantoki30032026PHILIPSBURG:---  The Honorable Prime Minister of Sint Maarten, Dr. Luc Mercelina, conveys his deepest condolences to the Government and people of Suriname following the passing of former President Chandrikapersad Santokhi.

Prime Minister Mercelina noted that former President Santokhi served his country with distinction and remained committed to the principles of democratic governance and regional cooperation.

“On behalf of the Government and people of Sint Maarten, I extend sincere condolences to the family of former President Santokhi, as well as to the Government and people of Suriname. His passing represents a moment of profound loss, and we stand in solidarity with Suriname during this period of national mourning,” stated Prime Minister Mercelina.

The Prime Minister also acknowledged the presence and contribution of the Surinamese community in Sint Maarten, recognizing the impact of this loss beyond Suriname’s borders.

“We also extend our sympathies to the Surinamese community in Sint Maarten, whose enduring cultural and familial ties to Suriname make this loss especially meaningful. During this difficult time, we stand with them in reflection and remembrance.”

Prime Minister Mercelina further reflected on Santokhi’s engagement within the Caribbean region and his contribution to strengthening partnerships among nations.

“Former President Santokhi will be remembered for his commitment to dialogue, cooperation, and the advancement of shared regional interests. His legacy will continue to resonate within the Caribbean community.”

The Government of Sint Maarten joins the regional and international community in expressing condolences and honoring the life and service of a leader.

Caption: Prime Minister Dr. Luc Mercelina and former President Santokhi during a bi-lat meeting between Suriname and St. Maarten during the United Nations General Assembly 2024.

Trust Fund’s Enterprise Support Project Completes US$20 million MSME Financing; Now Focused on Small Business Support Systems.

trustfund30032026Since 2020, the Trust Fund's Enterprise Support Project (ESP) has empowered more than 300 small businesses in Sint Maarten with loans and grants. The project, implemented by the National Recovery Program Bureau, was established to strengthen recovery efforts and increase the resilience of businesses on the island following Hurricane Irma's destruction in 2017. As ESP's financing activities are now complete, the project is moving to the next chapter of support. This phase is dedicated to creating enduring support systems for the long-term success of local businesses even after ESP closes in 2028. These systems aim to reach many more businesses across the island in the years to come.

Since applications for grants and loans closed in February 2025, $20.1 million in financing support has been disbursed to 325 Sint Maarten businesses. 39 percent of those beneficiaries were brand new start-ups, and just over 43 percent were run or owned by women. After receiving their loans and grants, 38 beneficiaries signed up for 8 months of tailored, one-on-one business coaching to refine their business acumen. Preliminary figures from an ESP survey showed the project supported over 600 jobs and contributed to a 30% increase in revenues for micro, small, and medium-sized enterprises (MSMEs) across sectors, including hospitality, transportation, healthcare, agriculture, and others.

Aside from direct funding for beneficiaries, ESP also increased accessibility to training programs by funding public courses. This meant some training was free or at a reduced cost for participants. Over 350 entrepreneurs participated in ESP-funded training and coaching. These included 221 entrepreneurs who trained through the Small Business Academy run by Qredits and 84 business owners who completed the Entrepreneurship Development Program delivered by the Sint Maarten Entrepreneurship Development Center (SEDC). These programs helped both new and established business owners improve skills like running daily operations, managing money, and planning for the future.

Now that the loans and grants phase is complete, ESP is shifting its focus to building government-led support systems for small businesses, enabling them to thrive long after the project officially closes in 2028.  ESP is working closely with the Ministry of Tourism, Economic Affairs, Transport, and Telecommunication (TEATT) to create permanent and well-organized services for entrepreneurs. Activities in the next phase include a detailed study of the challenges small businesses face in accessing local financing. It will also provide practical recommendations and solutions to solve those problems. ESP will develop standardized guidelines and procedures for operating and monitoring business support programs. For beneficiaries, the project is offering a new round of one-on-one coaching for long-term success. Finally, ESP will continue to monitor and evaluate business support efforts. It will also conduct a job survey to measure the real long-term impact of financing on beneficiaries’ businesses and job creation.

“ESP is a proven model for small business development. With the financing phase now complete, the project is focused on helping Sint Maarten’s small businesses have a bright future. The Ministry of TEATT is committed to making sure the right tools and support are in place for the island’s small businesses, both now and long after the Enterprise Support Project ends.” Honorable Minister of TEATT, Grisha Heyliger-Marten. 

 “Over the past six years, ESP has shown what is possible when you support entrepreneurs. More than 300 businesses benefited from financing and training, have strong repayment rates, and have contributed to job creation. Our focus now is working with TEATT to ensure that the support given by ESP can become a permanent part of how Sint Maarten serves small businesses.”  Claret Connor, NRPB Director.

Rose-Anne D. Wilson-Sagnia, Director of Sint Maarten Medical, is a beneficiary and coaching recipient. “I took advantage of everything ESP could offer me, from the financing to coaching. My slogan is ‘Dream only Big Dreams,’ and ESP allowed me to go beyond that and have even bigger dreams. The funding meant I could purchase quality, professional items, enabling me to get everything in place for my dream to become a reality. That’s the biggest perk for me; ESP allowed me to reach a higher level, so now I’m looking forward to growing my business. In the future, I’m considering more enterprises, franchises, and regional exposure. Yes, I am a small businessperson, but that doesn’t limit my aspirations.”

This new phase for the Enterprise Support Project aims to turn its successes and lessons into practical, long-lasting tools and systems. In turn, supporting the Government of Sint Maarten and its partners in their mission to help MSMEs grow in resilience and strength for many years to come.

ESP is implemented by the National Recovery Program Bureau on behalf of the Government of Sint Maarten. It is funded by the Sint Maarten Trust Fund, financed by the Government of the Netherlands, and managed by the World Bank.

IMF Urges Greater Transparency Reforms at Curaçao and Sint Maarten Central Bank.

cbcsimfreport30032026Washington, D.C./ WILLEMSTAD CURACAO:--- The International Monetary Fund (IMF) has called for deeper transparency reforms at the Centrale Bank van Curaçao en Sint Maarten (CBCS), warning that while the institution has made “significant progress,” key gaps in governance, communication, and public accountability still remain.

The findings come in the IMF’s latest Central Bank Transparency Code Review, which evaluates how effectively the CBCS communicates its policies, operations, and decision-making to the public and stakeholders.

Strong Progress, But Trust Still Recovering

The IMF acknowledged that the CBCS has taken meaningful steps in recent years to rebuild credibility after past financial sector failures that eroded public trust. Enhanced communication efforts, regulatory reforms, and modernization initiatives have helped restore confidence.

The report highlights that transparency is now central to the bank’s strategy, particularly as it operates across two countries—Curaçao and Sint Maarten—within a shared monetary union.

Notably, stakeholders have recognized improvements in communication, with over three-quarters reporting better transparency compared to previous years.

Transparency Strengths: Monetary Policy and Communication Gains

The IMF praised the CBCS for its high level of transparency in key policy areas, especially:

  • Monetary policy framework and objectives
  • Foreign exchange (FX) reserve management
  • Lender of last resort (LOLR) operations

The bank’s communication surrounding the launch of the Caribbean Guilder in 2025 was cited as a standout example, with effective messaging reaching a wide audience.

Additionally, the introduction of new reports—such as the Financial Stability Report—and increased use of newsletters and multilingual communication have strengthened public engagement.

Key Concerns: Governance, Communication, and Accountability Gaps

Despite progress, the IMF identified several structural weaknesses:

1. Weak Transparency in Governance

The report notes that while legal frameworks and mandates are publicly available, they are not sufficiently clear or comprehensive.

  • The hierarchy of the bank’s objectives is not clearly defined
  • Responsibilities of decision-making bodies lack transparency
  • Internal governance structures are not fully disclosed

This makes it difficult for stakeholders to fully understand how decisions are made.

2. Limited Disclosure of Government Interactions

The IMF raised concerns about minimal transparency in relations between the central bank and governments.

  • Little public information exists on agreements with public institutions
  • Parliamentary engagement is irregular and largely informal

The Fund suggested that regular reporting to both national parliaments would strengthen accountability and public trust.

3. Communication Strategy Needs Strengthening

Although communication has improved, challenges remain:

  • Messaging is not always accessible to all stakeholders
  • Website usability issues limit access to information
  • Some audiences—particularly in Sint Maarten—feel underserved

The IMF recommended publishing a formal communication strategy and simplifying technical content for broader understanding.

4. Gaps in Policy Transparency (FX and AML/CFT)

The report identified insufficient clarity in foreign exchange policies, particularly:

  • Lack of explanation of licensing rules
  • Limited disclosure of policy outcomes and rationale

Similarly, transparency around anti-money laundering (AML/CFT) supervision is uneven, with internal controls and enforcement outcomes largely undisclosed.

Major Recommendations

The IMF outlined a comprehensive reform agenda, including:

  • Clarifying the legal framework and institutional autonomy
  • Publishing governance structures, committee roles, and decision processes
  • Improving risk disclosure and internal audit transparency
  • Enhancing engagement with parliaments and public institutions
  • Publishing a formal communication strategy
  • Increasing transparency in FX policies and AML/CFT supervision

A Complex Operating Environment

The CBCS operates in a unique and challenging context as the central bank of a two-country monetary union. The financial system it oversees is large—exceeding 300% of GDP—and includes banks, insurers, and pension funds.

While the system remains broadly stable, past institutional failures have underscored the importance of transparency and effective supervision.

Looking Ahead

The IMF emphasized that the review is not a ranking exercise but a tool to help central banks align with global best practices.

For the CBCS, the path forward is clear: deepen transparency, improve communication, and strengthen accountability mechanisms to sustain public trust.

“The progress is notable,” the report concludes, “but further steps are needed to ensure transparency supports both independence and credibility.”

Conclusion

The IMF’s review underscores a broader global trend: central banks are increasingly judged not only by policy outcomes, but by how clearly and openly they communicate them.

For Curaçao and Sint Maarten, strengthening transparency at the CBCS will be critical—not just for institutional credibility, but for financial stability and public confidence in the years ahead.

 

Click here to read IMF Report.

CBCS Shares Outcome of IMF Transparency Code Review and Commits to Further Improvements.

Willemstad/Philipsburg:---  The Centrale Bank van Curaçao en Sint Maarten (CBCS) today presents the results of the IMF’s Central Bank Transparency (CBT) Code Review. The CBT Review is an in-depth assessment designed to evaluate how openly and clearly the CBCS communicates and operates across its core responsibilities, including governance, policy development, daily operations, performance reporting, and engagement with government and stakeholders. The CBCS welcomes the recommendations received to further enhance its transparency and strengthen the CBCS’ disclosures and communication practices.
Last year the CBCS requested the CBT review, reflecting its longstanding commitment to strengthening transparency, accountability, and public trust. The review provided the CBCS with a valuable opportunity for institutional reflection. The process engaged a multidisciplinary team across several divisions of the CBCS and enabled a comprehensive assessment of the CBCS’ transparency practices, including how information is disclosed to the public. In addition, the IMF administered a digital survey and conducted in-person meetings in both Curaçao and Sint Maarten to complement the assessment with input from key stakeholders. Collectively, these elements supported the identification of areas for improvement and targeted enhancements to further strengthen transparency and accountability. As the IMF notes, transparency is an essential pillar for supporting an effective central bank and safeguarding institutional credibility.
The CBCS notes that the IMF recognizes the significant strides made in recent years to enhance openness, communication, and stakeholder engagement. In its review, the IMF highlighted substantial improvements in the CBCS’ communication practices, including more frequent publications, multilingual outreach, expanded use of digital channels, and clearer reporting on core functions. Stakeholders surveyed by the IMF also acknowledged notable progress, giving the CBCS favorable ratings for overall transparency and accessibility of information.
The IMF further commended the CBCS for its highly transparent monetary policy framework, including clear disclosure of objectives, instruments, and the rationale for the currency peg. The review also praised the CBCS’ publication of comprehensive analyses such as the Financial Stability Report, its well-defined approach to reserve management, and its consistent communication of supervisory policies, consumer protection measures, and AML/CFT guidelines.
The CBCS reviewed all recommendations and has already identified concrete actions to further enhance transparency. All actions arising from the CBT Review have been integrated into the CBCS’ Strategic Plan 2026–2028, ensuring sustained commitment in the coming years.
“This exercise reflects our firm belief that transparency is essential to maintaining trust and ensuring that the public keeps us accountable,” stated CBCS President Richard Doornbosch. “We welcome the IMF’s constructive guidance and will continue to build on the progress already made.”
The CBCS thanks the IMF Mission Team for their professional and effective guidance during the mission. The Board also extends its sincere appreciation to CBCS staff for their dedicated support throughout the review process, as well as to external stakeholders for their constructive engagement and willingness to collaborate.
The detailed Central Bank Transparency Code Review Report is available on our website: https://www.centralbank.cw/about-the-bank/governance-risk-and-compliance


Willemstad, March30, 2026
CENTRALE BANK VAN CURAÇAO EN SINT MAARTEN


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