On Thursday 17th January 2019, Attorney’s-at-Law, Compliance Analysts, Mediators, Consultants and Financial Crimes Prevention Personnel converged at the Arthur Lok Jack Global School of Business, Mt. Hope campus to discuss Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) activities in the nation and outline pro-active counter-measures to combat these nefarious activities. The Seminar provoked insightful and interactive discussions around the topics of AML and CFT as participants were edified on their legal obligations with regard to reporting suspicious actions. Participants were also encouraged to assess their stakeholders and implement Enhanced Due Diligence (EDD) procedures when necessary to minimize risks of regulatory non-compliance.
The Compliance Seminar commenced with a special address from Ms. Susan Francois, Director, Financial Intelligence Unit of Trinidad and Tobago (FIU), who highlighted the legal AML and CFT obligations of institutions. Ms. Francois discussed the five (5) pillars of AML / CFT obligations, which were the adoption of a risk-based approach, written policies, procedures and controls, a designate Compliance Officer / Alternate Compliance Officer, a staff-training program and an independent audit of systems and controls. Institutions are required to implement these activities should they fall under the purview of the Central Bank of Trinidad and Tobago, the Trinidad and Tobago Securities Exchange Commission (the TTSEC) or the FIU; the three named Supervisory Authorities mandated to ensure that institutions comply with AML and CFT legislative and regulatory requirements.
Ms. Belinda James, Senior Director, Compliance, Caribbean Banking, RBC Financial (Caribbean) Limited was next on the agenda with a presentation on emerging risks and trends in AML. Some of the emerging risks identified were Trade-based Money Laundering, Virtual Currencies, Human Trafficking, Bribery and Corruption. Mr. Rennie Lakhan, Lecturer at UWI-ALJGSB / Senior Analyst, Ministry of Finance followed and took a deep dive on the topic of CFT through the analysis of case studies. This interactive segment stimulated thought provoking conversations around violent extremism and crime. During this segment Mr. Lakhan stated that Trinidad and Tobago would have high levels of crime once crime remains profitable. He went on to encourage participants to follow ‘clean money’ in addition to ‘dirty money’ to further reduce funding for terrorism and highlighted some indicators of possible terrorism financing which included travels to conflict zones.
The packed agenda continued with Ms. Dawne Spicer, Executive Director, Caribbean Financial Action Task Force, who gave a special address on where Trinidad and Tobago stands in accordance with global and regional standards of AML and CFT best practices. The Seminar concluded with Ms. Cindy Sadaphal, Attorney-at-Law, Co-Founder / Director of ACPTT who elaborated on the Enhanced Due Diligence measures that institutions could implement to prevent Terrorism Financing of financial products. These measures involved conducting a background scan on customers, determining a customer’s source of wealth and clearly identifying the reasons for undertaking a particular business activity.
At the end, participants of the Compliance Seminar 2019 were equipped with actionable counter measures and approaches that can be implemented to combat Money Laundering and Terrorism Financing. The knowledge gained would enable participants to adopt an effective AML / CFT risk management framework and compliance programme into their respective institutions thereby mitigating the risks associated with AML and CFT activities.