Report Types – Financial Intelligence Unit (2024)

Suspicious Transaction/Activity Reports (STRs/SARs)

The Proceeds of Crime Act(POCA) and theAnti -Terrorism Act(the ATA) require that a STR/SAR be made to the FIUTT by Reporting Entities when they know or have reasonable grounds for suspicion of Money Laundering or Financing of Terrorism. Suspicious Activity/ Suspicious Transaction Reports (STRs/SARs) suspicious transaction and suspicious activity reports are received from financial institutions and listed business in accordance with the Financial Intelligence Act.

What Is A Suspicious Transaction/Activity?

Suspicion of money laundering or financing of terrorism requires a degree of satisfaction that may not amount to belief, but should extend beyond mere speculation and be based on some foundation that money laundering or terrorist financing has occurred or is about to occur.

Suspicious Transaction/ Activity Report Form

Voluntary Information Reports (VIRs)

If any member of the public would like to provide information about suspicions of money laundering or of the financing of terrorist activities, a voluntary information report (VIR) can be submitted viamailto the FIUTT. If you believe that the information you provide is serious and requires an immediate law enforcement response, then you may also wish to provide this information directly to your local law enforcement agency.

Quarterly Terrorist Property Reporting (QTR)

Financial institutions are required to consult the list of designated entities and the Trinidad and Tobago Consolidated List of Court Orders and report to the FIUTT every three (3) months whether or not they are in possession of terrorist property (Section 33 (3) of the ATA). To ensure this obligation is fulfilled adequately, financial institutions are guided as follows:

  1. After confirmation that you ARE NOT in possession of terrorist property (that is, none of the financial institution’s customers appear on the United Nations Security Council Resolution (UNSCR) 1267/1989/2253 Sanctions List , the United Nations 1988 Sanctions Committee List and Trinidad and Tobago Consolidated List of Court Orders) a Quarterly Terrorist Property Report 1 (QTR1 form) must be submitted.

The FIUTT QTR 1 Form may be accessed here.

  1. After confirmation that you ARE in possession of terrorist property (that is, one of the financial institution’s customers appear on the United Nations Security Council Resolution (UNSCR) 1267/1989/2253 Sanctions List , the United Nations 1988 Sanctions Committee List and Trinidad and Tobago Consolidated List of Court Orders) a Quarterly Terrorist Property Report 2 (QTR2 form) must be submitted.

The FIUTT QTR 2 Form may be accessed here.

Financial institutions should note further that once a Terrorist Funds Report was previously submitted to the FIUTT, they will now be required to submit the QTR2 quarterly once they are still in possession of the terrorist property.

For information on how to complete and submit the QTR forms, please consult the FIUTT’sGuidance to Financial Institutions on the Procedures for Submitting Quarterly Terrorist Reports.

Economic Sanctions Reporting (ESR)

The purpose of the Economic Sanctions (Implementation of United Nations Resolution on the Democratic Republic of Korea) Order, 2018 and the Economic Sanctions (Implementation of United Nations Resolution on the Islamic Republic of Iran) Order, 2023 is to implement measures to prevent and disrupt the financing of the proliferation of weapons of mass destruction which constitutes a substantial threat to both domestic and international peace and security.

Pursuant to these Orders, eachFinancial Institution (FI) and Listed Business (LB) must have regard to Clause9 (1) which provides that, when the Attorney General circulates the list ofentities which have been the subject of a freezing Order by the Supreme Courtof Judicature of Trinidad and Tobago, the FI or LB MUST immediately inform the FIU where any of the following apply –

  1. The Financial Institution or Listed Business has knowledge or reasonably suspects that any entity named in the Court Order has property or funds within the Financial Institution or Listed Business; or
  2. There is a transaction being conducted by a person involving property or funds owned or controlled, whether directly or indirectly, by an entity named in the Court Order in the form made by the Economic Sanctions Act, Chap 81:05,the Economic Sanctions Reporting Form

See more on Guidance Note

Terrorist Funds Report

In accordance with section 22AB ofthe Anti -Terrorism Act (the ATA), as amended, all FIs and LBs must reportTerrorists’ Funds immediately and without delay to the FinancialIntelligence Unit (the FIUTT).

All Reporting Entities are required to consult the United Nations Security Council Resolution (UNSCR) 1267/1989/2253 Sanctions List , the United Nations 1988 Sanctions Committee List and Trinidad and Tobago Consolidated List of Court Orders) to verify whether any designated entity or listed entity has funds in the financial institution or listed business.

  1. After consulting the Lists, if the Reporting Entity knows or has reasonable grounds to believe that a designated entity or listed entity has property or funds in Trinidad and Tobago, the Reporting Entity MUST IMMEDIATELY WITHOUT DELAY take the following action:
    1. Orally, via telephone, inform the FIUTT, that they have property or funds belonging to an individual or legal entity falling into a category identified; and
    2. Complete the Terrorist Funds Report (the “FIU TFR form”) and
    3. Submit the completed FIU TFR form electronically, by the secure reporting system established by the FIUTT; or
    4. Submit the completed FIU TFR form in hard copy by hand in a sealed envelope.

UNDER NO CIRc*msTANCES SHOULD A REPORTING ENTITY ENTER INTO OR CONTINUEA BUSINESS WITH A DESIGNATED OR LISTED ENTITY

See more on Guidance Note

Strategic Reports

Strategic analytical reports areproduced from the FIUTT’s study of large sets of data from multiple STRs/SARsand other sources to identify patterns, future trends and typologies. Suchanalysis assists in intelligence-led policing and policy formation. In this reporting period the FIUTT initiatedwork on Strategic Analysis products which include Human Trafficking, Corruptionand Drug Trafficking.

I'm an expert well-versed in the realm of financial regulations and anti-money laundering (AML) practices, possessing a profound understanding of the Suspicious Transaction/Activity Reports (STRs/SARs) landscape. My expertise extends to the relevant legal frameworks, including the Proceeds of Crime Act (POCA) and the Anti-Terrorism Act (ATA). Allow me to demonstrate my in-depth knowledge by delving into the key concepts mentioned in the article.

The article emphasizes the obligation of Reporting Entities, as per POCA and the ATA, to submit STRs/SARs to the Financial Intelligence Unit of Trinidad and Tobago (FIUTT) when they have reasonable grounds to suspect money laundering or financing of terrorism. These reports are received from financial institutions and listed businesses in accordance with the Financial Intelligence Act.

A critical point highlighted is the definition of a suspicious transaction/activity, emphasizing that suspicion should be based on some foundation beyond mere speculation. This aligns with international standards that require a degree of satisfaction indicating potential money laundering or terrorist financing.

The article mentions the availability of a Suspicious Transaction/Activity Report Form and the option for the public to submit Voluntary Information Reports (VIRs) regarding suspicions of money laundering or terrorist financing. The latter can be sent via mail to the FIUTT.

Financial institutions are also mandated to submit Quarterly Terrorist Property Reports (QTR) to the FIUTT every three months. The process involves confirming whether they are in possession of terrorist property and submitting the appropriate form based on the outcome. The article provides links to the QTR1 and QTR2 forms.

Economic Sanctions Reporting (ESR) is another crucial aspect covered, where financial institutions and listed businesses must inform the FIU if entities subject to a freezing order have property or funds within their jurisdiction. This aligns with measures to prevent the financing of weapons of mass destruction.

The article further outlines the requirement for Reporting Entities to report Terrorists' Funds immediately under the ATA. Entities must consult designated lists and, if necessary, inform the FIUTT orally and submit the Terrorist Funds Report electronically or in hard copy.

Lastly, the article introduces the concept of Strategic Reports, which involves analyzing large sets of data from multiple STRs/SARs to identify patterns and trends. The FIUTT uses this analysis for intelligence-led policing and policy formation, with specific focus areas mentioned, such as Human Trafficking, Corruption, and Drug Trafficking.

In conclusion, my expertise allows me to dissect and explain the intricate details of the article, demonstrating a comprehensive understanding of the regulatory landscape surrounding suspicious transactions, terrorist financing, and economic sanctions.

Report Types – Financial Intelligence Unit (2024)
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