The Bankers Association of Trinidad and Tobago (BATT) notes with concern the recent pronouncements by the Financial Action Task Force (FATF) on the Anti-Money Laundering and the Countering of the Financing of Terrorism (AML/CFT) regime of Trinidad and Tobago.
The FATF public statement, which was issued on November 3rd 2017, identified Trinidad & Tobago as one of nine (9) countries as having strategic AML/CFT deficiencies with the other countries namely Bosnia and Herzegovina, Ethiopia, Iraq, Sri Lanka, Syria, Tunisia, Vanuatu and Yemen. Trinidad and Tobago committed to the execution of an action plan, which is yet to be realized.
The text of the statement as it relates to Trinidad and Tobago is reproduced below:-
In October 2017, Trinidad and Tobago made a high-level political commitment to work with the FATF and CFATF [the Caribbean FATF] to strengthen the effectiveness of its AML/CFT regime and address any related technical deficiencies. Trinidad and Tobago will work to implement its action plan to accomplish these objectives, including by: (1) adopting and implementing the relevant measures to enhance international cooperation; (2) addressing measures for transparency and beneficial ownership; (3) completing the legislative efforts to enhance the processing of ML [Money Laundering] charges before the courts; (4) taking measures to enhance tracing and confiscation of criminal assets; (5) enforcing TF [Terrorist Financing] measures and adopting appropriate measures for NPOs [Non Profit Organizations]; (6) enacting the necessary amendments related to targeted financial sanctions; and (7) developing, adopting, and implementing the necessary framework to counter proliferation financing.
BATT advises that this FATF Statement has serious implications to local banks and the national community at large and can translate into severe economic challenges generally for all. There will be impact to banking operations locally if international correspondent banking relations become strained as a result.
The FATF list is a signal to banks globally to take precautionary measures with respect to their dealings with banks, clients, and transactions from territories on the FATF list. This statement along with Trinidad and Tobago’s slow implementation of the Common Reporting Standard (CRS) will place Trinidad and Tobago businesses in a disadvantageous position when negotiating with their international counterparts.
Trinidad and Tobago will also be given a higher country risk ranking and all wire and other international transactions from and the operations of local banks will be subject to greater scrutiny. This may lead to further pressures on an already tenuous correspondent banking relationships and a greater threat of loss of same, thus endangering our already tight foreign exchange flows. There will be higher cost of doing international/ cross border transactions, which will translate into higher cost of doing business locally. A challenging situation in already challenging economic times.
We urge the Government of Trinidad and Tobago to take the requisite steps to expeditiously and urgently execute on the agreed action plan, which involves for the most part, the strengthening of the several institutions responsible for the administration and enforcement of the AML /CFT regime in Trinidad and Tobago.