Financial Crime World

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

Introduction

The Anti-Money Laundering (AML) and Combating of Terrorist Financing (CTF) guidelines outlined in this document provide a comprehensive framework for financial institutions in Trinidad and Tobago to adhere to. These guidelines are designed to prevent money laundering and terrorist financing, while ensuring the integrity of the financial system.

Key Obligations

The following are key obligations of financial institutions under the AML/CTF framework:

Financial Institutions

  • The guidelines apply to various types of financial institutions, including:
    • Banks
    • Cambios
    • Bureaus de change
    • Companies engaged in money transmission or remittance business
    • Insurance companies

Compliance Programmes

  • Financial institutions must establish and maintain a compliance programme that includes:
    • Documentation
    • Identification of customers
    • Record-keeping
    • Training
    • Anonymous accounts
    • Shell banks
    • Politically exposed persons
    • Correspondent banking
    • Wire transfers

Suspicious Transaction Reporting

  • Institutions must report complex, unusual or large transactions with no apparent economic or visible lawful purpose to the Finance Intelligence Unit (FIU) of Trinidad and Tobago.

Legislative Framework

  • The guidelines are based on relevant legislation, including:
    • Prevention of Money Laundering Act (POCA)
    • Financial Institution Regulations (FOR)
    • Anti-Terrorism Act (ATA)

Supervisory Authority

  • The Central Bank is designated as the Supervisory Authority for financial institutions that it regulates, allowing it to take regulatory measures to ensure compliance with AML/CTF requirements.

Application of Guidelines

The guidelines apply to all financial institutions in Trinidad and Tobago, including insurance companies. If an insurance company has a salesman or agent who is conducting business, they must implement an Anti-Money Laundering (AML) and Combating of Terrorist Financing (CTF) compliance programme. This includes identifying customers, maintaining records, and reporting suspicious transactions.

Similarly, if the same insurance company has a branch in another country, it must assess the AML/CTF regime existing in that jurisdiction and comply with the higher standards required by Trinidad and Tobago laws, to the extent permitted by the host jurisdiction’s laws and regulations.