The Financial Intelligence Unit of T&T (FIU) is reminding financial institutions and listed businesses of their legal obligation to submit Suspicious Transaction/Activity Reports (STRs/SARs) to the FIU, during the transition period to the new $100 polymer, where they know or reasonably suspect that the funds used for the transaction are the proceeds of criminal conduct or related to the financing of terrorism.
In a statement issued yesterday, the FIU said that any person who knowingly contravenes or fails to comply with the provisions of the law, commits an offence and is liable on summary conviction, to a fine of $500,000 and imprisonment for a term of two years, and on conviction on indictment, to a fine of $3 million and imprisonment for a term of seven years.
The FIU pointed to the Proceeds of Crime Act, which states: “Where a financial institution or listed business knows or has reasonable grounds to suspect that funds being used for the purpose of a transaction… are the proceeds of criminal conduct, the financial institution or listed business shall make a suspicious transaction or a suspicious activity report to the FIU.”
The FIU also referred to the Anti Terrorism Act, which states that “Where a financial institution or listed business knows or has reasonable grounds to suspect that funds are linked or related to, or to be used for terrorism, terrorist acts, or by the terrorist organisations or those who finance terrorism, the financial institution or listed business shall make a suspicious transaction or suspicious activity report to the FIU.”