How to create a Compliance Program ?

A Compliance Program (CP) is a manual that contains the internal policies and procedures of a listed business. The Know Your Customer (KYC) forms are attached as appendices to the compliance program.

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What are the key elements of a Compliance Program?

The staring point is that there must be a risk based approach in the Anti-Money Laundering (AML) Compliance Program.

The four (4) pillars of an effective Anti-Money Laundering (AML) Compliance Program are:

  1. The development of internal policies, procedures, and related controls;
  2. The designation of a competent and qualified Compliance Officer;
  3. Ongoing AML training for all staff, directors of the listed business;
  4. Independent review of the Compliance Framework by a competent and qualified AML auditor.

About the Author: Antoinette Sydney LLB LEC CAMLFC CFRMP, Bar No. SYA2015211, Attorney at Law. The author is the first Online Lawyer based in Trinidad and Tobago. Her entire Law Practice is based Online using technology. Client meetings are conducted at mutually convenient meeting points. She has clients in Guyana, St Vincent, Barbados, the British Virgin Islands and North America. She specializes in Corporate Law and Anti-Money Laundering Compliance. She helps clients to start their Online Business Empire.

Check out my Online Companies:

Call/Whatsapp for a quotation 868 373-1166


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Instagram: @asydneygrouptt



I am a Certified Professional in the following areas:


Corporate Training;

Anti-Money Laundering and Financial Crimes;

Fraud Risk Management;

Graphic Design.

Services include:

Anti-Money Laundering (AML) Training for staff, directors;

Anti-Money Laundering Audits;

Compliance Program drafting;

Consulting services and much more.

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What is CFT? :Countering the Financing of Terrorism:AML Compliance Consultants

What is Terrorism?
Terrorism is the calculated, premeditated use of unlawful violence to cause panic or advance a political, religious, ideological cause.

Financing of Terrorism
Funding of terrorism involves providing funds from both legal (personal donations and profits from businesses and charitable organizations ) and or illegal sources (the drug trade, the smuggling of weapons and other goods, fraud, kidnapping and extortion), directly or indirectly or knowing that the monies are to be used to finance terrorism activity or organizations according to FINTRAC.


Terrorism is financed in order to:
Promote militant ideology;
Purchase food for recruits;
Purchase weapons;
Pay operatives;
Arrange for travel;
Train new recruits;
Forge documents;
Pay bribes;
Acquire land;
Stage attacks.

How to proceed when it is discovered that a potential or existing customer is a terrorist ?
As soon as a financial institution or listed business receives the list of designated entities or the consolidated list referred to in section 22AA(2)(c) or (e), the following procedures shall apply:
(a) the financial institution shall immediately inform the FIU on the prescribed form, if any person or entity named on either list has funds with the financial institution or listed business;
(b) if the financial institution or listed business has reasonable grounds to believe that a person or entity named on either list has funds in Trinidad and Tobago, it shall immediately inform the FIU on the prescribed form;
(c) (Deleted by Act No. 14 of 2012); and
(d) if a person or entity named on that list attempts to enter into a transaction or continue a business relationship, the financial institution or listed business shall submit a suspicious activity report to the FIU immediately and shall not enter into or continue a business transaction or business relationship with such person or entity.

The law requires that the transaction and by extension, the business relationship be brought to an end and a Suspicious Activity/Transaction Reported be submitted by the Compliance Officer to the FIU.

Anti Terrorism Act of Trinidad and Tobago,PART III FINANCING OF TERRORISM 22AB

The author is an attorney at law in Trinidad. She specialises in Anti Money Laundering and Financial Crimes. Website

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