Financial Institutions Must Tighten Up Anti-Money Laundering Measures

Amendments to Financial Obligations Regulations, 2010

The Port of Spain, Trinidad and Tobago has amended its Financial Obligations Regulations, 2010, requiring financial institutions and listed businesses to strengthen their anti-money laundering measures.

Enhanced Customer Due Diligence

Financial institutions and listed businesses must now obtain additional information when dealing with customers who are:

• Trustees
• Nominees
• Fiduciaries

This includes evidence of the appointment of the trustee, the nature and purpose of the trust, and verification of the identity of the trustee.

Due Diligence and Verification

Financial institutions and listed businesses must perform due diligence on customers and identify any discrepancies in the information provided. If a discrepancy is found:

• The institution must make every effort to obtain correct information
• May even discontinue business with the customer if the information cannot be verified

Prohibited Activities

Financial institutions and listed businesses are prohibited from:

• Maintaining anonymous accounts or accounts in fictitious names
• Permitting shell banks to use their accounts

Correspondent Banks

Correspondent banks must:

• Collect sufficient information about their respondent banks to understand the nature of their business and assess their anti-money laundering controls
• Obtain approval from senior management before establishing new correspondent relationships

Insurance Companies

Insurance companies are subject to customer due diligence provisions, which require them to:

• Identify parties entering into insurance contracts
• Establish the true nature of principals if the party is acting on behalf of a principal

Monitoring and Compliance

The Trinidad and Tobago Financial Intelligence Unit (TFIU) will be responsible for monitoring compliance with the regulations and investigating any suspicious transactions or activities.

Key Takeaways:

• Obtain additional information from customers who are trustees, nominees or fiduciaries
• Perform due diligence on customers and identify any discrepancies in the information provided
• Do not maintain anonymous accounts or accounts in fictitious names
• Collect sufficient information about respondent banks and assess their anti-money laundering controls
• Identify parties entering into insurance contracts and establish the true nature of principals if acting on behalf of a principal

Contact Information:

For more information, please contact the Trinidad and Tobago Financial Intelligence Unit (TFIU) at [insert contact information].