Compliance Officer Duties in Trinidad and Tobago: A Critical Role in AML/CFT Compliance Regime

Introduction

In an effort to ensure effective implementation of anti-money laundering (AML) and combating the financing of terrorism (CFT) measures, every supervised entity in Trinidad and Tobago is required to appoint a compliance officer (CO) and alternate compliance officer (ACO). This article outlines the duties and responsibilities of the CO and ACO in Trinidad and Tobago’s AML/CFT compliance regime.

Compliance Officer Responsibilities

The CO is responsible for:

Overseeing the entity’s AML/CFT compliance regime
Implementing policies and procedures approved by senior management
Submitting suspicious transaction reports to the Financial Intelligence Unit of Trinidad and Tobago (FIUTT)

Alternate Compliance Officer Responsibilities

The ACO performs the duties of the CO in their absence, ensuring continuity of the business’s reporting obligations.

Qualifications and Training

To take up the role, the CO and ACO must:

Be well-trained and suitable to perform the tasks
Possess decision-making authority
Undergo approval by the FIUTT

The appointment process begins with the submission of a Compliance Officer Fit and Proper Questionnaire, which is reviewed for compliance with internal processes and checks. The entity will be notified in writing of the FIUTT’s decision.

Ongoing Requirements

Supervised entities may need to provide updated data information to the FIUTT from time to time, including:

Changes to registered addresses
Mailing addresses
Information relating to the CO and ACO
Government-issued picture IDs and citizenship details

The FIUTT encourages entities to use its new FIUTT Data Update Form to facilitate this process.

Conclusion

The compliance officer plays a critical role in ensuring Trinidad and Tobago’s financial institutions operate within a robust AML/CFT framework, protecting the country from illicit activities and maintaining international standards of transparency and accountability.