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Anti-Money Laundering (AML) and Combating Terrorist Financing (CTF) Guidelines in Trinidad and Tobago

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Applicability

The guidelines outlined below apply to financial institutions operating in Trinidad and Tobago, including:

  • Authorized dealers (e.g., cambios and bureaus de change)
  • Companies engaged in money transmission or remittance business
  • Insurance companies
  • Banks and other financial institutions

Key Obligations

Financial institutions must adhere to the following key obligations:

  • Establish a Compliance Program: Develop and implement an effective AML/CTF compliance program.
  • Appoint a Compliance Officer: Designate a qualified individual as Compliance Officer, responsible for overseeing AML/CTF efforts.
  • Maintain Records: Document, establish, and maintain accurate records of customer information, transactions, and suspicious activities.
  • Report Suspicious Transactions: Inform the Finance Intelligence Unit (FIU) about any suspicious transactions or activities.
  • Implement AML/CTF Programs Abroad: Ensure that branches and subsidiaries operating in foreign jurisdictions adhere to local AML/CTF regulations and standards.

Regulatory Framework

The guidelines are based on the following laws and regulations:

  • Proceeds of Crime Act (POCA)
  • Financial Institution (Anti-Money Laundering and Combating the Financing of Terrorism) Regulations 2008 (FOR)
  • Other relevant laws

The Central Bank is responsible for supervising financial institutions, with powers to take enforcement actions as needed.

Group Risk Management

Financial institutions must:

  • Assess Jurisdictional Risks: Evaluate AML/CTF regimes in jurisdictions where their branches or subsidiaries operate.
  • Apply Higher Standards: If local requirements exceed those in Trinidad and Tobago, apply stricter standards to ensure compliance.
  • Access Subsidiary Information: Ensure access to information about subsidiary operations is available to maintain effective risk management.