Financial Crime World

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TERRORISM (AMENDMENT) ACT #2 OF 2010: SECTION 5(E)

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Financial Institutions on High Alert for Terrorist Financing

In light of the ongoing threat of terrorism, financial institutions in Trinidad and Tobago are being urged to remain vigilant and take proactive measures to prevent the financing of terrorist activities. According to Section 5(e) of the Terrorism (Amendment) Act #2 of 2010, financial institutions are required to implement anti-money laundering (AML) and combating of terrorist financing (CTF) programs to detect and report suspicious transactions.

Sources of Terrorist Financing

Terrorist groups often rely on two primary sources of funding:

  • State-sponsored terrorism
  • “Revenue-generating” criminal activities, including:
    • Large-scale smuggling
    • Fraud
    • Theft
    • Narcotics trafficking
    • Legitimate sources such as community solicitation and fundraising appeals

Guideline on AML/CTF

The Central Bank has issued a Guideline on Anti-Money Laundering and Combating of Terrorist Financing, which outlines the requirements for financial institutions to implement AML/CTF programs. The guideline applies to:

  • Licensed banks
  • Insurance companies
  • Authorized dealers
  • Money transmission/remittance companies

Applicability of the Guideline

The guideline is applicable to all financial institutions operating in Trinidad and Tobago, including branches and subsidiaries abroad. Financial institutions are required to assess the AML/CTF regime existing in any jurisdiction where their branches or subsidiaries operate and apply the higher standard if permitted by host country laws.

Legislative and Regulatory Framework

Section 2.1(a) of the guideline names the relevant AML/CTF legislation that applies to all regulated financial institutions, including:

  • Prevention of Money Laundering and Financing of Terrorism Act (POCA)
  • Financial Intelligence Unit of Trinidad and Tobago
  • Other relevant laws and regulations

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