Financial Crime World

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

Introduction

The Anti-Money Laundering (AML) and Combating Terrorist Financing (CTF) guideline in Trinidad and Tobago outlines the legislative and regulatory framework for AML/CTF, the responsibilities of financial institutions, and the requirements for compliance.

Definition of Financial Institutions

  • Authorized dealers (i.e., cambios and bureaus de change), registered under the Exchange Control Act.
  • Insurance companies.
  • Companies engaged in money transmission or remittance business under the Central Bank Act Chapter 79:02.
  • Agents of money remitters.

Responsibilities of Financial Institutions

  • Compliance Program: Implement AML/CTF compliance programs, including:
    • Documenting and maintaining a compliance program.
    • Appointing a Compliance Officer.
    • Reporting suspicious transactions.
    • Cooperating with regulatory authorities.
  • International Cooperation: Assess the AML/CTF regime in any jurisdiction where branches or subsidiaries operate and adhere to higher standards if local laws permit.

Legislative Framework

  • The Prevention of Crime Act (POCA) requires financial institutions to implement specific measures, including:
    • Documenting and maintaining a compliance program.
    • Appointing a Compliance Officer.
    • Reporting suspicious transactions.
    • Providing information to the Finance Intelligence Unit (FIU).
  • The Financial Institutions Regulations (FOR) require financial institutions to comply with AML/CTF requirements.

Regulatory Measures

  • The Central Bank can take regulatory measures, such as enforcement actions, to ensure compliance with AML/CTF requirements.

Terrorist Financing Regulations

  • The Anti-Terrorism Act (ATA) establishes a quarterly reporting regime for possession or control of terrorist property.
  • The Financial Intelligence Unit of Trinidad and Tobago Act (FIUTTA) requires suspicious transaction reporting where there are reasonable grounds to suspect that a transaction is related to the commission of a terrorist act.