Under the anti-money laundering and counter financing of terrorism laws, financial institutions and listed businesses, must develop a Policy Document (Compliance Programme) in order to establish operational procedures that will assist employees and officers to prevent and deter criminal activities associated with money laundering, fraud and terrorist financing.
This Policy Document must support the initiatives in Combating Money Laundering and the Financing of Terrorism, of individual Governments throughout the Caribbean region. The Policy Document also seeks to ensure that appropriate systems are implemented in the organisation so as to ensure compliance with relevant legislative requirements in order to prevent the organization and individuals from costly fines and imprisonment.
Credit Unions in Trinidad and Tobago and the wider Caribbean region and by extension, world over, are continuously challenged to come up with more innovative ways of delivering quality, efficient and effective service to their membership, thus creating opportunities for improving and sustaining their competitiveness. Failure to do so could have grave consequences on their ability to effectively compete and maintain relevance in the financial marketplace.
In Trinidad and Tobago, the relevant pieces of legislation and regulations are:
- Proceeds of Crime Act No.55 of 2000 and its amendments
- The Financial Obligations Regulations (Amendment) 2014, and amendments
- The Financial Intelligence Unit of Trinidad and Tobago Act. No.11 of 2009, and its amendments
- The Financial Intelligence Unit of Trinidad and Tobago (Amendment) Act. No. 3 of 2011
- The Financial Intelligence Unit of Trinidad and Tobago Regulations, 2011, and its amendments
- Miscellaneous Provisions (Financial Intelligence Unit of Trinidad and Tobago and Anti - Terrorism) Act, 2012
- Miscellaneous Provisions (Proceeds of Crime, Financial Intelligence Unit of Trinidad and Tobago and Anti - Terrorism) Act, 2014
- Miscellaneous Provisions (Mutual Assistance in Criminal Matters, Proceeds of Crime, Financial Intelligence Unit of Trinidad and Tobago, Customs and Exchange Control) Act, 2018 (Act No 2 of 2018)
- The Anti-Terrorism Act No. 26 of 2005, and its amendments
- The Financial Obligations (Financing of Terrorism) Regulations, 2011, and itsamendments
In conformity with the above legislations and regulations, some of the obligations of financial institutions and listed businesses are:
- Training of all members of staff and directors
- Reporting of SARs / STRs
- Develop and implement a Compliance Programme
- Monitor Client Accounts
- Conduct independent Internal and External Compliance Audit
- Maintain Records
- Implement Customer Due Diligence Procedures
- Develop staff vetting procedures
- Obtain Customer Identification
- Appoint a Compliance and Alternate Compliance Officer
- Report Terrorist Funds
The above obligations are required to protect the integrity of the financial system and to prevent the financial institutions and listed businesses from incurring huge penalties and fines, inclusive of possible imprisonment of persons representing the organisations. All employees and Officers are required to abide by the relevant legislation and regulations.
At MSD we are cognizant that the aforementioned legislations and regulations will impact the way you our valued customer interact and conduct business with your membership. As a result, to aid organizations in fulfilling their obligations, and maintain compliance with this critically important legislation, we are continuously assessing the rapid changes taking place within the AML/CFT environment, making the requisite changes within our flagship product Emortelle, which resulted in the implementation of a number of features and processes outlined below.
- Automatic transaction alert via email and text.
- Suspicious activity and transaction report.
- Threshold Transaction Reporting [TTR].
- Electronic generation of source of funds form.
- Electronic picture and signature identification.
- Automatic expiration alert of ID’s [Passport, Drivers Permit, and National ID].
- Preventative and Detective controls on the transaction and product level.
- A Comprehensive Audit and Transaction activity log.
MSD will continue to work with you our valued customer to ensure that any additional requirements to meet your AML/CFT obligations within Emortelle are made available.
As we move forward together on the journey of providing second to none quality customer service to you, our valued customer, we will continue to fuse IT with traditional customer service, ensuring we remain true to our brand promise “Committed to customer satisfaction, software excellence and integrity”.