Enforcement Statistics

as at September 30, 2020

Number of Entities subject to Enforcement by the Financial Intelligence Unit of Trinidad and Tobago(FIUTT) according to the following breaches:

NoNature of BreachNumber of Entities
1Failure to register in accordance with Section 18B of the FIUTT Act Chap 72:01563
2Failure to appoint a Compliance Officer (CO) and alternate Compliance Officer (ACO) and seek approval of the FIUTT in accordance with Regulation 3 and 4 of the Financial Obligations Regulations, 201062
3Failure to submit quarterly terrorist property reports to the FIUTT in accordance with Section 33(3) of the Anti-Terrorism Act Chap 12:07218
4Failure to rectify deficiencies identified at a compliance examination in accordance with Section 57 of the Proceeds of Crime Act, Chap 11:2779
TOTAL922
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Escalated Enforcement Action

Where a supervised entity fails to respond to enforcement action initiated by the FIUTT, the matter is escalated in accordance with the FIUTT’s Enforcement Policy that adopts a tiered approach to sanctioning.  As such, if an entity fails to respond to a warning letter issued via registered mail, the entity is served a notice to appear before the Director of the FIUTT to make representation accordingly.  Consequently, a directive is issued instructing the entity to comply within a specific timeframe.  If there is no compliance thereafter, the matter is referred to the High Court of Justice of the Republic of Trinidad and Tobago.  The information below refers.

(a) Directives Issued

One Hundred and Fifty-one (151) entities were issued with Notices to appear for a FIU hearing pursuant to section 18H FIU Act.  One Hundred and Two (102) Directives were issued in total. Fifty-five (55) Directives have been issued for failure to register with the FIU and for AML deficiencies subsequent to a compliance examination

Forty- Seven (47) Directives were issued prior to the legislative amendment of the Financial Obligations Regulations in 2014 for failure to submit a Compliance Programme.

(b) Court Orders Obtained

In the matter of an Application under Section 18(H) (8) of the Financial Intelligence Unit of Trinidad and Tobago Act
The Financial Intelligence Unit of Trinidad and Tobago (Claimant) vs Varona Limited (Defendant)
C. Aboud, James J
Date of Delivery – 06.09.2016

  • Claim No. CV2014-00862In the matter of an Application under Section 18(G) (8) of the Financial Intelligence Unit of Trinidad and Tobago ActThe Financial Intelligence Unit of Trinidad and Tobago (Claimant) v New World Members Club Limited (Defendant)Dean-Armorer, Mira JDate of Delivery – 08.05.2014
  • Claim No. CV2014-00863In the matter of an Application under Section 18(G) (8) of the Financial Intelligence Unit of Trinidad and Tobago ActThe Financial Intelligence Unit of Trinidad and Tobago (Claimant) v Jerry’s Club Limited (Defendant)Charles, Joan JDate of Delivery – 10.06.2014