Trinidad and Tobago's Financial Intelligence Unit (FIU) has submitted 16 cases to law enforcement agencies for investigation. Two of the cases were closed by the Financial Investigations Bureau (FIB) of the Trinidad and Tobago Police Service as "no further action could be taken." This information was disclosed in the FIU's 2011 annual report. In 2011, the number of suspicious activity reports (SAR) increased to 303 from 111 in 2010. Seventy-one of those cases were closed in 2011 while 219 are cited as "ongoing analysis."
The report explained that not all SARs were forwarded to law enforcement agencies because the FIU oftimes acts as a catalyst. "A STR/SAR is only a report of suspicion. If the FIU's subsequent analytical study tends to substantiate the suspicion of money laundering, or a predicate offence lending to money laundering or organised crime, the analytical report and supporting documentation are forwarded to law enforcement agencies for investigations," the report said. The monetary value of the SARs in 2011 was $304.1 million-more than three times 2010's value of $85.7 million. Of the 303 SARs-151 originated from the banking sector, 90 from money/value transfer, 28 from investment companies, nine from the insurance sector, 14 from mortgage companies, five from co-operative societies, two from attorneys, one from motor vehicle sales and three from real estate.
Acting FIU director Susan Francois attributes the increase to growing awareness of the FIU in T&T. The FIU has 1,465 businesses registered. Among them are: 565 attorneys- at- law, 109 accountants, 172 Co-operative societies, 100 motor vehicle sales, 89 Jewellers, 341 real estate agencies, 35 Private Members' clubs, four money or value transfer services, eight pool betting, four gaming houses, and one national lotteries on-line betting games. However, many registered businesses failed to submit compliance reports by the end of May 2011.
Speaking at a Compliance Conference on Anti Money Laundering at Hyatt yesterday, Francois said while the law has a penalty for non-compliance, the FIU has not imposed any penalty to date. The FIU, she said, favours a "co-operative, no surprises approach to ensuring compliance. "It is believed that most supervised entities are making a sincere effort to comply with their obligations under Trinidad and Tobago's AML/CFT laws. The FIUTT is committed to working constructively with supervised entities to assist them to understand and comply with their obligations," the report said.
"If these efforts are unsuccessful or if the supervised entity continues to be in non-compliance, the FIUTT will take the necessary steps to impose legal sanctions," it said. While the annual report outlined the role and activities undertaken throughout the financial year, there was no accounting for monies spent from its annual budgetary allocation. The report observed that while much work was accomplished, much more needs to be done. "To this end, support must be given to legal, law enforcement, regulatory and intelligence agencies (including the FIUTT) to fulfil their AML responsibilities," it said.