Financial Institutions in Trinidad and Tobago Must Comply with Stringent AML/CFT Regulations

The Financial Intelligence Unit (FIU) has emphasized the importance of several key areas that financial institutions and listed businesses must implement to ensure compliance with anti-money laundering and combating the financing of terrorism (AML/CFT) regulations in Trinidad and Tobago.

Compliance Requirements

Compliance Officer and Alternate Compliance Officer

Financial institutions are required to appoint a Compliance Officer and an alternate Compliance Officer, who will be responsible for developing and implementing a comprehensive AML/CFT program. This program must include:

• Staff training on AML/CFT issues
• Risk-based approaches to identifying potential suspicious transactions
• Internal controls to prevent fraud
• Reporting obligations for suspicious activities

Record-Keeping Obligations

Financial institutions are mandated to retain certain records in electronic or written form for a period of six years. These records include:

• All domestic and international transactions
• Identification data obtained through customer due diligence
• Account files and business correspondence
• Results of analysis undertaken related to an account transaction

These record-keeping obligations enable financial institutions to comply with lawful requests from auditors, other competent authorities, and law enforcement agencies for information related to criminal investigations or prosecution of individuals charged with criminal offenses.

Registers and Reporting Obligations

Compliance Officers are required to maintain several registers that contain sensitive information about suspicious transactions, training records, and internal reviews. These registers must be easily accessible by senior management and auditors, but should not include confidential correspondence or information about suspects. Some of the key registers that financial institutions in Trinidad and Tobago must maintain include:

• Training Register: tracks staff training on AML/CFT issues
• Internal STR Register: records suspicious transactions identified by staff
• STR Register: captures reports submitted to the FIU
• LEA Register: logs law enforcement agency requests for information

Consequences of Non-Compliance

Failure to comply with these regulations can result in severe penalties, including fines and even criminal prosecution. As such, it is essential that financial institutions take proactive steps to ensure compliance with AML/CFT regulations and maintain accurate records of their activities.

By following these guidelines, financial institutions in Trinidad and Tobago can demonstrate their commitment to combating money laundering and the financing of terrorism, while also protecting themselves from potential penalties and reputational damage.