Financial Crime World

Here’s the article in markdown format:

Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Regulations in Trinidad and Tobago

===============

Introduction

In this article, we’ll be discussing key points related to anti-money laundering and combating the financing of terrorism (AML/CFT) regulations in Trinidad and Tobago. Specifically, we’ll focus on sections 19-23 and 24.

Section 19: Politically Exposed Persons

Definition and Requirements

  • A politically exposed person (PEP) is defined as a person who holds or has held a prominent public position.
  • Financial institutions must implement measures to determine if an applicant or account holder is a PEP.
  • If a PEP is identified, additional due diligence measures are required to assess the risk associated with doing business with them.
  • Permission from a senior management official is necessary before establishing a business relationship with a PEP.

Section 21: Correspondent Banking

Definition and Requirements

  • Correspondent banking refers to the relationship between two banks, where one bank acts as an intermediary for the other bank’s transactions.
  • A financial institution must collect sufficient information about its respondent bank to understand their business nature and assess their anti-money laundering controls.
  • The institution must obtain approval from senior management before establishing new correspondent relationships.

Section 22: Shell Banks

Prohibition on Correspondent Banking with Shell Banks

  • A shell bank is a bank that is incorporated in a jurisdiction without a physical presence, or unaffiliated with a financial group regulated by a supervisory authority in a country where the Financial Action Task Force (FATF) recommendations are applicable.
  • A bank shall not enter or continue a correspondent banking relationship with a shell bank.

Section 23: New Technologies and Money Laundering Patterns

Monitoring New Technologies for Money Laundering Patterns

  • A financial institution must pay special attention to money laundering patterns that may arise from new technologies that favor anonymity.
  • The institution must take appropriate measures to treat these patterns and prevent them from being used for illicit activities.