Financial Obligations Regulations 2010: Anti-Money Laundering (AML) and Combating Terrorism Financing (CFT)

The Financial Obligations Regulations 2010 of Trinidad and Tobago outline the requirements for anti-money laundering (AML) and combating terrorism financing (CFT) in the country. This article provides a summary of the key aspects of these regulations.

Politically Exposed Persons

Financial institutions and listed businesses must identify and verify the identity of applicants for business, account holders, and beneficial owners who are politically exposed persons (PEPs). A PEP is defined as an individual who has held or exercises a prominent public position, such as:

• Head of state
• Government minister
• High-ranking official

Correspondent Banking

Correspondent banking refers to the provision of banking services by one bank in Trinidad and Tobago (the correspondent bank) to another bank (the respondent bank) in a foreign country. The correspondent bank must:

• Collect sufficient information about its respondent bank, including understanding the nature of their business relationship
• Assess the respondent bank’s AML/CFT controls

Shell Banks

A shell bank is defined as a bank that has no physical presence in any country or jurisdiction. Financial institutions and listed businesses are prohibited from establishing correspondent banking relationships with shell banks unless they are affiliated with a financial group regulated by a supervisory authority in a country where the FATF Recommendations are applicable.

Non-Face-to-Face Business Relationships

Financial institutions and listed businesses must pay special attention to money laundering patterns that may arise from new or developing technologies that favor anonymity. They must also put special know-your-customer policies in place to address specific concerns associated with non-face-to-face business relationships or transactions, including:

• Monitoring for suspicious transactions
• Conducting enhanced due diligence on high-risk customers
• Implementing robust customer verification and identification processes

Important Note

These explanations are general summaries of the regulations. Financial institutions and listed businesses must consult the actual regulations for a detailed understanding of their obligations and requirements.