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Anti-Money Laundering and Combating Terrorist Financing in Trinidad and Tobago

The Guideline on Anti-Money Laundering and the Combating of Terrorist Financing in Trinidad and Tobago outlines key requirements for financial institutions to prevent money laundering and terrorist financing activities. Here are some essential points that can be inferred from this guideline:

Definition of Financial Institutions

Financial institutions regulated under the Exchange Control Act, Central Bank Act Chapter 79:02, and insurance companies must implement anti-money laundering/combating terrorist financing (AML/CTF) compliance programs.

Examples of Regulated Financial Institutions

  • Changios and bureaus de change
  • Companies engaged in money transmission or remittance business
  • Insurance companies

Compliance Requirements

Financial institutions must:

  • Document their AML/CTF policies
  • Appoint a Compliance Officer
  • Train employees on AML/CTF procedures
  • Report suspicious transactions to the Financial Intelligence Unit (FIU)

International Application

Financial institutions with branches or subsidiaries abroad must ensure that AML/CTF requirements are implemented in these jurisdictions as well. If local laws prohibit this, the Central Bank must be notified.

Legislative Framework

The Proceeds of Crime Act (POCA) and the Financial Services Commission of Trinidad and Tobago’s (FSC) FOR contain additional obligations related to:

  • Customer identification
  • Record-keeping
  • Training
  • Other aspects

Group Risk Management Strategy

For non-deposit-taking subsidiaries, financial institutions must ensure access to information about their operations and activities to comply with AML/CTF laws and regulations. Both international and group risk management strategies should be part of the overall compliance program.

Enforcement Actions

The Central Bank can enforce regulatory measures under the legislation governing particular financial institutions, including the FIA and IA.

By implementing effective AML/CTF policies and procedures, financial institutions in Trinidad and Tobago can prevent money laundering and terrorist financing activities.