Curaçao Finance Minister questions Integrity of Jardin appointment, Central Bank response cites legal caps

WILLEMSTAD--Curaçao’s Minister of Finance Javier Silvania has raised serious concerns over the recent appointment of José Jardim, former Financial and Economic Director at the Central Bank of Curaçao and Sint Maarten (CBCS), as CEO of Banco di Caribe, a financial institution that was until recently under CBCS supervision.

In a letter dated July 8, addressed to the CBCS Supervisory Board, Silvania questioned the speed, transparency, and ethical considerations surrounding Jardim’s transition, citing potential risks to the integrity of the financial system.

Silvania argued that such a rapid move from a regulatory position to an executive role at a regulated entity could pose significant conflicts of interest. He referenced international standards, such as the European Central Bank’s mandatory one-year “cooling-off” period for similar cases, and noted that in some industries, waiting periods can extend to two years.

“In Jardim’s case, only a brief internal restriction period was applied, starting even before his actual departure from the CBCS,” Silvania wrote, calling the move disproportionate given Jardim’s prior strategic oversight role.

The Minister also criticized the lack of consultation with his office and a perceived absence of transparency in the approval process. He warned of reputational risks, possible legal ramifications, and erosion of public trust if regulators are seen to be circumventing their own standards.

Silvania has formally requested the Supervisory Board to provide:

A review of the timeline and procedures of Jardim’s transition,
Information on how his new appointment was vetted and approved,
Clarity on any role Jardim may have played in the sale of Banco di Caribe, and
A full explanation of the CBCS’s policies on post-employment conduct and integrity.

𝐂𝐞𝐧𝐭𝐫𝐚𝐥 𝐁𝐚𝐧𝐤 𝐑𝐞𝐬𝐩𝐨𝐧𝐝𝐬, 𝐀𝐜𝐤𝐧𝐨𝐰𝐥𝐞𝐝𝐠𝐞𝐬 𝐋𝐞𝐠𝐚𝐥 𝐆𝐚𝐩𝐬

In a response issued on July 13, the Supervisory Board of the CBCS emphasized that although there are no current legal provisions in the Central Bank Statute regulating such transitions, appropriate safeguards were applied throughout the process.

The Board stated it fully acknowledges and shares the concerns raised by Minister Silvania, and assured that these were considered during the handling of Jardim’s resignation. The CBCS confirmed that it is willing to meet with the Minister to discuss the matter further.

The Board explained that existing legislation lacks any mandated procedures for transfer, resignation, or cooling-off periods for CBCS executives. Nevertheless, it claimed that the transition was managed carefully, including a parallel and independent assessment of Jardim’s candidacy by De Nederlandsche Bank (DNB), which was required due to Banco di Caribe’s status as a supervised institution.

Importantly, the CBCS noted that a draft revision of the Bank Statute, being developed in coordination with the International Monetary Fund (IMF), does include provisions for a formal cooling-off period. This revised statute is expected to be submitted to the governments of Curaçao and Sint Maarten later this year.

While the Supervisory Board’s statement attempts to reinforce confidence in the integrity of the process, it also implicitly highlights a gap in the current regulatory framework, an absence that Minister Silvania argues could leave the financial system exposed to reputational and ethical risks.

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