Financial Crime World

Trinidad and Tobago: Crucial Information for Financial Institutions on AML/CFT Compliance Obligations

The Financial Intelligence Unit (FIU) in Port of Spain, Trinidad and Tobago, outlines essential legal obligations for registered financial institutions and listed businesses following their registration. These requirements ensure adherence to Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) provisions.

Key Compliance Obligations in Trinidad and Tobago

  1. Compliance Officer and alternate Compliance Officer: Financial institutions and listed businesses must designate a Compliance Officer and an alternate to oversee the development and implementation of policies and procedures to meet AML/CFT regulatory requirements.
  2. Compliance Programme: Developing a comprehensive programme to mitigate money laundering and terrorist financing risks is a mandatory requirement.
  3. AML/CFT Training: Staff training is essential to ensure understanding of the AML/CFT legislative framework and risks.
  4. Risk-Based Approach: Financial institutions and listed businesses must adopt a risk-based approach in identifying, assessing, and managing risks.
  5. Internal Controls: Establishing internal controls is crucial for effective implementation and monitoring of AML/CFT programmes.
  6. Reporting Obligations: Financial institutions and listed businesses must report any suspicious transactions to the FIU and maintain associated records.
  7. Independent Testing: Regular independent testing is necessary to evaluate the effectiveness of AML/CFT policies and procedures.

Record Keeping: a Crucial Aspect of Regulatory Compliance

Maintaining accurate records is essential in upholding these commitments. Financial institutions and listed businesses must keep the following records for a minimum of six (6) years:

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

Key Registers for Financial Institutions and Listed Businesses

Maintaining the following registers will help financial institutions and listed businesses effectively respond to lawful information requests and provide transparency and accountability for audits and regulatory scrutiny.

  1. Training Register: This register should document dates and times, facilitator names, participant names, covered topics, and attendant signatures.
  2. Internal Suspicious Transaction Report (STR) Register: This register should include staff submission dates, suspected nature of transactions, transaction values, and review dates by the Compliance Officer.
  3. External STR Register: This register should document submission dates to the FIU, suspected nature of transactions, transaction values, and Compliance Officer signatures.
  4. Law Enforcement Agencies (LEA) Register: This register should include enquiry dates and natures, investigating agency and officer names, and the powers being exercised.

The registers should exclude sensitive client details or confidential correspondences. Providing easily accessible information offers transparency and accountability for audits and regulatory scrutiny.