Can a citizen voluntary provide information to the FIU in Trinidad?

Yes!! Citizens can provide information concerning suspected money laundering or suspected terrorist financing to the Financial Intelligence Unit (FIU) via a Voluntary Information Reports (VIRs).

This is submitted to the FIU via mail. Members of the public are also sdvised to inform law enforcement agencies (LEA). 

Antoinette Sydney LB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.

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Are Non Profit Organizations (NPOs) supervised by the Financial Intelligence Unit (FIU)?

Recommendation 8 of the Financial Action Task Force mandates that counties assess the adequacy of the laws and regulations with respect to Non-Profit Organizations (NPOs). NPOs are susceptible to being used to finance terrorism. In 2019, the   Non-Profit Organizations Act No. 7 of 2019 (NPOA) was enacted and is in effect.

By virtue of this piece of legislation, NPOs now fall under the ambit of AML/CFT/PF regime in Trinidad and Tobago.

The Financial Intelligence Unit (FIU) is the supervisor of NPOs that earn more than $500,000 in gross annual income.

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.

Order her new book now: How to Hustle from Home: 50 Success Secrets
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Disclaimer:
The content herein is only for informational and educational purposes and does not constitute legal advice. Please be advised that no attorney/client relationship is created by the publishing of this content. You should consult with your attorney at law for independent legal advice.

No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

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What is the goal Financial Action Task Force (FATF) Non-Cooperative Countries and Territories (NCCT) List?

The principal aim of the Non-Cooperative Countries and Territories (NCCT) Initiative was to reduce the vulnerability of the global financial system to money laundering by ensuring that all financial centres adopt and implement measures for the prevention, detection and prosecution of money laundering according to internationally standards.

 Jurisdictions that are subject to the FATF’s call for countermeasures or are subject to enhanced due diligence (EDD) due to their strategic AML/CFT deficiencies (black list)[1]

Click to access FATF-Public-Statement-June-21-2019.pdf


[1] http://www.fatf-gafi.org/publications/high-riskandnon-cooperativejurisdictions/documents/public-statement-november-2017.html

Antoinette Sydney LLB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.

Order her new book now: How to Hustle from Home: 50 Success Secrets
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Disclaimer:
The content herein is only for informational and educational purposes and does not constitute legal advice. Please be advised that no attorney/client relationship is created by the publishing of this content. You should consult with your attorney at law for independent legal advice.

No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

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Process to escalate a Suspicious Activity Report STR/SAR to Compliance Officer

Staff will submit a written internal Suspicious Activity Report or Suspicious Transaction Report (SAR/STR) to the Compliance Officer.

After an internal SAR/STR is submitted to the Compliance Officer(CO) ,  and the CO determines whether the SAR/STR should be submitted to the FIU.

 The FIU cannot speculate the criminal offence it must be explicitly stated.

The internal SAR is a version of the FIU’s SAR/STR template, it is usually a form contained in the Compliance Program.

The Compliance Officer relies on the in the internal SAR so the intelligence provided by frontline staff is crucial.Intelligence goes from employee to the Compliance Officer, then Compliance Officer to the Financial Intelligence Unit.

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.

Order her new eBook now: How to Hustle from Home: 50 Success Secrets
Get a free sample of two chapters here
https://linktr.ee/asydneygrouptt

Website: www.asydneygroup.com

Email: sydney@asydneygroup.com

Blog: https://sydneygroupblog.wordpress.com/

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Disclaimer:
The content herein is only for informational and educational purposes and does not constitute legal advice. Please be advised that no attorney/client relationship is created by the publishing of this content. You should consult with your attorney at law for independent legal advice.

No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

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What happens after a SAR/STR is made in Trinidad

The Financial Intelligence Unit (FIU) receives the SAR/STR and analyses it. If there is a criminal offence the FIU prepares an Intelligence Report (IR) and forwards it to the Fraud Squad or the Financial Investigative Branch (FIB) of the Trinidad and Tobago Police Service (TTPS) or the Anti-Corruption Unit of the TTPS.

An investigation is then launched based on the intelligence contained in the Intelligence Report. The FIU is supposed to “sanitize” the information by removing names of reporting employee and the Compliance Officer.

Fraud Squad, Financial Investigative Branch , or the Anti-Corruption Investigative Branch (ACIB)  will start visiting the premises of the suspect, asking questions, looking for witnesses, providing the DPP with information in order to receive instructions to start preparing charges.

FIU may be asked for additional information such as any other SARs/STRs reported in the past.

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.

Order her new eBook now: How to Hustle from Home: 50 Success Secrets
Get a free sample of two chapters here
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Blog: https://sydneygroupblog.wordpress.com/

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Disclaimer:
The content herein is only for informational and educational purposes and does not constitute legal advice. Please be advised that no attorney/client relationship is created by the publishing of this content. You should consult with your attorney at law for independent legal advice.

No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

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What should an Individual Customer Information Form (CIF) contain

Customer Information

Full name;

Date & Country of birth;

Nationality-Important to determine whether the customer is a Non Resident

Permanent Residential Address-PO Box or Bag addresses will not suffice

Email Address

Verification of Customer identity and Address

2 forms of valid, government issued , photo ID

Permanent Address-The customers address must be reflected on the Proof of Address submitted, ie TTEC,WASA, CABLE,.

Employer’s name & contact #-By contacting the employer , all doubts as to the veracity of the job letter will be removed. It will be revealed whether the customer is actually employed by the company on the job letter.

Occupation/Nature of Business-For self employed persons, sole traders. Submit proof eg job letter, payslip.;

Occupational Income-Submit proof eg job letter, payslip.

If self employed-Please state what services or products are offered and provide proof;

Are you a Non Resident ?-Please provide foreign bank reference letter.

Beneficial Owner Information

The Name of the Beneficial Owner-The natural person(s) who ultimately owns or controls a customer and/or the natural person on whose behalf a transaction is being conducted. It also includes those persons who exercise ultimate effective control over a legal person or arrangement.” FATF

Politically Exposed Person (PEP)

Source of Wealth Declaration (only applies to PEPs and High risk Customers) .

Source of Wealth– refers to the origin of the customer’s entire body of wealth, ie their total assets- since they are PEPs , they are more susceptible to bribes and corruption

Source of Funds Declaration ( applies to all customers)

Source of funds refers to the activity that generated the funds and the location thereof to be used to finance the transaction eg salary payments in savings account at ACB.

Customer Declaration

Signature of Customer

For Compliance Review

UN 2253 List;

FATF Non-Cooperative Countries and Territories;

TT Consolidated List of Court Orders;

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.

Blog: https://sydneygroupblog.wordpress.com/

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Disclaimer:
The content herein is only for informational and educational purposes and does not constitute legal advice. Please be advised that no attorney/client relationship is created by the publishing of this content. You should consult with your attorney at law for independent legal advice.

No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

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Registers to be maintained by a regulated entity for the purposes of the Regulator : AML Compliance Consultant

Record keeping is a major part of Anti-Money Laundering. As such , the following registers must be kept for the regulators as well as the auditors:

Register of Correspondence received from the regulator;

Register of Internal Suspicious Activity Reports (SARS) received from staff;

Register of Suspicious Activity Reports (SARS) and Suspicious Transaction Reports (STRs) submitted to the regulator;

Register of Law Enforcement Request for Information.

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.

Blog: https://sydneygroupblog.wordpress.com/

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Disclaimer:
The content herein is only for informational and educational purposes and does not constitute legal advice. Please be advised that no attorney/client relationship is created by the publishing of this content. You should consult with your attorney at law for independent legal advice.

No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

Should LB/FIs reference new and existing employees against the Sanctions Lists: AML Compliance Consultants

It is good practice to reference the name of new and existing staff against Sanction Lists. Regulation 5 of the Financial Obligation Regulations requires that financial institutions and listed businesses use the best practices of the industry to recruit employees who have integrity and are competent.

This practice will ensure that individuals who are designated as terrorist or terrorist financiers are not retained by the regulated entity.

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP an author and entrepreneur based in Trinidad and Tobago.

Blog: https://sydneygroupblog.wordpress.com/

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Disclaimer:
The content herein is only for informational and educational purposes and does not constitute legal advice. Please be advised that no attorney/client relationship is created by the publishing of this content. You should consult with your attorney at law for independent legal advice.

No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

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How are Art Dealers used to wash dirty money?: Free Anti Money Laundering Training in Trinidad!!

One of my friends is an artist and she tells me of here adventures. She once told me that at one of her art shows a customer saw her painting, went for her cheque book and was prepared to buy my friend’s piece. The lady issued a cheque payable to my friend’s personal name. In order to advance her career my friend must be close with art dealers and art galleries. She told me that the art galleries take a commission for each painting that the artist sells.

I attended my friend’s art exhibition and I was amazed at the people in the crowd. They were mainly well-dressed professionals. Everyone was refined and sipped on the complimentary wine. The prices of the paintings ranged from $1200.00 TTD to $200,000.00 TTD. I became curious as to how money launderers can abuse art dealers to launder money.

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  1. High value artwork can be purchased with cash obtained from criminal activities and then re-sold to another purchaser for more than the purchase price. This second purchaser can pay via cheque with the payee being the Art Dealer. The dirty money has been laundered and the proceeds from the sale of the artwork will appear legitimate because the funds will pass through a financial institution when the cheque is encashed.
  2. Artwork can be purchased with dirty money and shipped to another country where it will be sold at a profit. This allows for the cross-border movement of a high valued asset.
  3. A money launderer can purchase artwork at a low price with funds from illegal activity and then use the services of an auctioneer to sell the art to the highest bidder. The auctioneer can be paid in cash with money gained from the proceeds of crime.
  4. An art dealership can be registered, an art gallery can be opened to display art. The expenses of the art dealership such as rent and salaries can be paid with dirty money.
  5. After purchasing artwork with dirty money, the high valued art can be used as collateral for a loan application with a financial institution or money lending service.
  6. An artist can be hired to forge rare pieces of art and these can be sold to unsuspecting customers, who think that they are being the original.
  7. Pieces of art from a young and upcoming artist can be purchased and then can be sold in a few years when and if the artist becomes famous.
  8. The money launderer can connect with companies who want to contribute artwork to a Charity. The artwork that will be sold to the company can be purchased at minimal cost. The owner of a charity here in Trinidad told me about an instance where he asked for sponsorship from a big local company. The company donated almost $100,000 TTD in artwork to his cause.
  9. Art work can be purchased cheaply and then sold online to anyone interested in the piece. Naturally the piece will be sold for more than the purchase price.
  10. Expensive artwork can be stolen from a museum and then sold privately to an interested buyer.

The nature of these art sales is usually private and this makes it ideal for those desirous of washing money. In Trinidad and Tobago, art dealers are regulated by the Financial Intelligence Unit and must appoint a compliance officer, create a compliance program, attend anti-money laundering training and conduct anti-money laundering audits.

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.

Blog: https://sydneygroupblog.wordpress.com/

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Disclaimer:
The content herein is only for informational and educational purposes and does not constitute legal advice. Please be advised that no attorney/client relationship is created by the publishing of this content. You should consult with your attorney at law for independent legal advice.

No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

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New $50,000 Source of Funds Declaration (SOFD) threshold in Trinidad and Tobago

In Trinidad and Tobago, for the purposes of completing a Source of Funds Declaration (SOFD)  a large transaction is now $50,000TTD according to Legal Notice No. 356 of 2019.

The Miscellaneous Provisions (Proceeds of Crime and Central Bank) Act No 22, 2019 has amended Section 55 (3C) of the Proceeds of Crime Act Chap. 11:27 (POCA) and Regulation 11 (1) of the Financial Obligations Regulations (FORs), 2010. 

It follows that your Anti-Money Laundering/Countering the Financing of Terrorism Proliferation Financing Compliance Program must be updated to reflect this change. A suspicious transaction can also be below this $50,00 threshold and reporting entities can file Suspicious Transaction Reports for transactions that fall below this amount.

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP is an author and entrepreneur based in Trinidad and Tobago.

Blog: https://sydneygroupblog.wordpress.com/

Linked In: https://tt.linkedin.com/in/antoinette-sydney-77093550

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Facebook: https://www.facebook.com/sydneygrouptt/

Youtube: https://www.youtube.com/channel/UC8-sUa8WMDJM8w5_Q3nhQ5w

Disclaimer:
The content herein is only for informational and educational purposes and does not constitute legal advice. Please be advised that no attorney/client relationship is created by the publishing of this content. You should consult with your attorney at law for independent legal advice.

No representations or warranties are made about the suitability, comprehensiveness and or accuracy of the information and other content contained on this channel. It should be noted that legal information and content can become out of date and I give no undertaking to keep this blog up to date. All liability for any loss or damage of any kind which may be suffered as a result of accessing and using the information and or content of this blog is hereby excluded to the full extent permitted by law.

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