Gail Alexan­der

Se­nior Po­lit­i­cal Re­porter

The Fi­nan­cial In­tel­li­gence Unit of T&T (FI­UTT) re­ceived a to­tal of 950 Sus­pi­cious Trans­ac­tion and Sus­pi­cious Ac­tiv­i­ty Re­ports (STRs/SARS) from en­ti­ties in 2023 val­ued at $5.9 bil­lion—and a 93 per cent in­crease was not­ed by non-reg­u­lat­ed fi­nan­cial in­sti­tu­tions such as cred­it unions.

The FI­UTT al­so iden­ti­fied 41 cred­it unions that were in breach of the oblig­a­tion to sub­mit Quar­ter­ly Ter­ror­ist Prop­er­ty Re­ports with­in the spec­i­fied time­frame.

This was not­ed yes­ter­day by Fi­nance Min­is­ter Colm Im­bert in a state­ment to Par­lia­ment on the FI­UTT’s an­nu­al re­port for the year end­ed Sep­tem­ber 30, 2023. It was laid in Par­lia­ment.

At Sep­tem­ber 30, 2023, some 4,821 su­per­vised en­ti­ties were op­er­at­ing un­der the FI­UTT’s An­ti-Mon­ey Laun­der­ing/Counter Fi­nanc­ing of Ter­ror­ism/Counter Pro­lif­er­a­tion Fi­nanc­ing (AML/CFT/CPF) su­per­vi­sion.

The FI­UTT, which us­es in­tel­li­gence pro­vid­ed from the analy­sis of STRs and SARs in its work, stat­ed that in the re­port­ing pe­ri­od, it re­ceived a to­tal of 950 STRs/SARs) which were sub­mit­ted by re­port­ing en­ti­ties.

Im­bert said, “The bank­ing sec­tor con­tin­ues to record the high­est num­ber of STRs/SARs, ac­count­ing for 60 per cent of the to­tal STRs/SARs re­ceived.

“This was fol­lowed by the Mon­ey or Val­ue Trans­fer Ser­vices sec­tor and Co-op­er­a­tive So­ci­eties, which ac­count­ed for 23 per cent and eight per cent of the to­tal STRs/SARs re­ceived re­spec­tive­ly.”

The FI­UTT not­ed a 21 per cent de­crease in STRs/SARs sub­mis­sions from the bank­ing sec­tor and a no­table in­crease from fi­nance com­pa­nies, from three to 29, or an 867 per cent in­crease when com­pared to the pre­vi­ous re­port­ing pe­ri­od.

“Sub­mis­sions from the Mon­ey or Val­ue Trans­fer Ser­vices sec­tor and Co-op­er­a­tive So­ci­eties in­creased by 113 per cent and 55 per cent re­spec­tive­ly. Over­all, a 93 per cent in­crease was not­ed in the STRs/SARs sub­mis­sions by non-reg­u­lat­ed fi­nan­cial in­sti­tu­tions—cred­it unions,” Im­bert added.

How­ev­er, a 19 per cent de­crease was not­ed in sub­mis­sions by fi­nan­cial in­sti­tu­tions and a 17 per cent de­crease in sub­mis­sions from list­ed busi­ness­es.

The FI­UTT not­ed a 250 per cent in­crease in STRs/SARs sub­mis­sions from pri­vate mem­bers’ clubs and a 25 per cent in­crease in the STRs/SARs sub­mis­sions from mo­tor ve­hi­cle sales.

The to­tal mon­e­tary val­ue of the 950 STRs/SARs re­ceived amount­ed to $5,954,472,732, of which 784 (TT$1,392,564,730) were com­plet­ed trans­ac­tions and rep­re­sent­ed a 12 per cent de­crease when com­pared to the pre­vi­ous re­port­ing pe­ri­od.

“Some 226 were at­tempt­ed trans­ac­tions, of which the mon­e­tary val­ue amount­ed to TT$4,561,908,002 and rep­re­sent­ed a sig­nif­i­cant in­crease over the pre­vi­ous re­port­ing pe­ri­od. No­tably, sev­en STRs/SARs con­tained both com­plet­ed and at­tempt­ed trans­ac­tions,” Im­bert added.

The FI­UTT com­plet­ed analy­sis on 523 STRs/SARs, gen­er­at­ing a to­tal of 60 in­tel­li­gence re­ports, of which 51 were sus­pect­ed mon­ey laun­der­ing cas­es and nine sus­pect­ed fi­nanc­ing of ter­ror­ism cas­es.

Based on the sub­mis­sions of Quar­ter­ly Ter­ror­ist Prop­er­ty Re­ports, the FI­UTT ob­served that there’s been an in­crease in aware­ness among re­port­ing en­ti­ties, ev­i­denced through the ex­pan­sion of their due dili­gence process­es.

Dur­ing the re­port­ing pe­ri­od, the FI­UTT utilised three main tools to test whether in­ter­nal con­trols were ef­fec­tive­ly im­ple­ment­ed by su­per­vised en­ti­ties. In the area of in­de­pen­dent test­ing, in­de­pen­dent au­dits were con­duct­ed in high­er-risks sec­tors, in­clud­ing at­tor­neys, pri­vate mem­bers’ clubs, cred­it unions, mo­tor ve­hi­cle sales and re­al es­tate.

He said, “In the area of com­bat­ing mon­ey laun­der­ing, the fi­nanc­ing of ter­ror­ism and pro­lif­er­a­tion fi­nanc­ing, while no laws spe­cif­ic to the do­mes­tic An­ti-Mon­ey Laun­der­ing/Counter Fi­nanc­ing of Ter­ror­ism/Counter Pro­lif­er­a­tion Fi­nanc­ing (AML/CFT/CPF) regime have been passed, pro­posed amend­ments to leg­is­la­tion geared to­wards the im­prove­ment of T&T’s com­pli­ance with the Fi­nan­cial Ac­tion Task Force (FATF) rec­om­men­da­tions (24, 25 and 35) have en­gaged the FI­UTT.”

The FI­UTT re­ceived 13 re­quests from for­eign au­thor­i­ties dur­ing 2023, which fea­tured 38 sub­jects. Sus­pect­ed crim­i­nal con­duct in the ma­jor­i­ty of cas­es was mon­ey laun­der­ing re­lat­ed. The FI­UTT al­so made 18 re­quests to for­eign au­thor­i­ties for fi­nan­cial in­tel­li­gence and in­for­ma­tion.