Trinidad & Tobago
Trinidad and Tobago is on the FATF List of Countries that have been identified as having strategic AML deficiencies
Latest FATF Statement - 18 October 2019
In November 2017, Trinidad and Tobago made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime and address any related technical deficiencies. The FATF has made the initial determination that Trinidad and Tobago has substantially completed its action plan and warrants an on-site assessment to verify that the implementation of Trinidad and Tobago’s AML/CFT reforms has begun and is being sustained, and that the necessary political commitment remains in place to sustain implementation in the future. Specifically, Trinidad and Tobago has made the following key reforms: (1) adopting and implementing the relevant measures to enhance international cooperation; (2) addressing measures for transparency and beneficial ownership; (3) completing the legislative efforts to enhance the processing of ML charges before the courts; (4) taking measures to enhance tracing and confiscation of criminal assets; (5) enforcing TF measures and adopting appropriate measures for NPOs; (6) enacting the necessary amendments related to targeted financial sanctions; and (7) developing, adopting, and implementing the necessary framework to counter proliferation financing.
Compliance with FATF Recommendations
The last Mutual Evaluation Report relating to the implementation of anti-money laundering and counter-terrorist financing standards in Trinidad and Tobago was undertaken by the Financial Action Task Force (FATF) in 2016. According to that Evaluation, Trinidad and Tobago was deemed Compliant for 12 and Largely Compliant for 13 of the FATF 40 Recommendations.
US Department of State Money Laundering assessment (INCSR)
Trinidad and Tobago is categorised by the US State Department as a Country/Jurisdiction of Primary Concern in respect of Money Laundering and Financial Crimes.
Trinidad and Tobago’s geographic location, generally stable economy, and developed financial systems make it vulnerable to money laundering.
In November 2017, Trinidad and Tobago developed an action plan to address deficiencies noted by international experts. Throughout 2018, Trinidad and Tobago has done much to improve its AML regime.
Despite substantial and continuing efforts to reform the criminal justice system, a lengthy judicial process can still mean years before criminal prosecutions are resolved. While the number of persons charged with money laundering-related offenses continues to increase, there has not yet been a stand-alone conviction for money laundering. Continued legislative and institutional reforms, including adequate resources and implementation, are needed to ensure the proper enforcement of Trinidad and Tobago’s AML regime.
EU Commission Tax Blacklist
Trinidad and Tobago has been attributed a rating of “Non Compliant” by the Global Forum on Transparency and Exchange of Information for Tax Purposes, has not signed and ratified the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters as amended, has a harmful preferential tax regime and did not commit to addressing these issues by 31 December 2018.
Trinidad and Tobago's commitment to comply with criteria 1.1 and 3 will be monitored.
On March 12, 2019, the EU Commission confirmed that Trinidad and Tobago had major transparency concerns and, therefore, it will remain on the EU Tax Blacklist.
There are no international sanctions currently in force against this country.
BRIBERY & CORRUPTION
Rating (100-Good / 0-Bad)
Transparency International Corruption Index 41
World Governance Indicator – Control of Corruption 44
Trinidad and Tobago attracts considerable foreign direct investment from international businesses, particularly in energy, and has one of the highest per capita incomes in Latin America. Economic growth between 2000 and 2007 averaged slightly over 8% per year, significantly above the regional average of about 3.7% for that same period; however, GDP has slowed down since then, contracting during 2009-2012, making small gains in 2013 and contracting again in 2014-2015.
Energy production and downstream industrial use dominate the economy. Trinidad and Tobago produces about nine times more natural gas than crude oil on an energy equivalent basis with gas contributing about two-thirds of energy sector government revenue. Oil and gas account for about 40% of GDP and 80% of exports but less than 5% of employment. In 2013, Trinidad and Tobago was the world’s sixth-largest liquefied natural gas (LNG) exporter and is home to one of the largest natural gas liquefaction facilities in the Western Hemisphere. The United States is the country’s largest trading partner, accounting for 33% of its total imports and taking 44% of its exports.
Trinidad and Tobago is buffered by considerable foreign reserves and a sovereign wealth fund that equals about one-and-a-half times the national budget, but the country is in a recession and the government faces the dual challenge of gas shortages and a low price environment. A projected 70% decrease in energy revenue to the government in 2016 will likely force cuts to the government budget, which has increased by 35% over the past six years.
Economic diversification is a longstanding government talking point, and Trinidad and Tobago has much potential due to its stable, democratic government and its educated, English speaking workforce. Although Trinidad and Tobago enjoys cheap electricity from natural gas, the renewable energy sector has recently garnered increased interest. The country is also a regional financial centre with a well-regulated and stable financial system. Other sectors the Government of Trinidad and Tobago has targeted for increased investment and projected growth include tourism, agriculture, information and communications technology, and shipping. Unfortunately, a host of other factors, including low labour productivity, inefficient government bureaucracy, and corruption, have hampered economic development.
Agriculture - products:
cocoa, dasheen, pumpkin, cassava, tomatoes, cucumbers, eggplant, hot pepper, pommecythere, coconut water, poultry
petroleum and petroleum products, liquefied natural gas (LNG), methanol, ammonia, urea, steel products, beverages, food processing, cement, cotton textiles
Exports - commodities:
petroleum and petroleum products, liquefied natural gas, methanol, ammonia, urea, steel products, beverages, cereal and cereal products, cocoa, fish, preserved fruits, cosmetics, household cleaners, plastic packaging
Exports - partners:
US 26.3%, Argentina 12%, Brazil 6.6%, Chile 5.3%, Dominican Republic 5.2%, Barbados 5% (2015)
Imports - commodities:
mineral fuels, lubricants, machinery, transportation equipment, manufactured goods, food, chemicals, live animals
Imports - partners:
US 35.6%, China 6.8%, Gabon 6.6% (2015)
Investment Climate - US State Department
The two islands of Trinidad and Tobago (TT) are located in the Lesser Antilles, between the Atlantic Ocean and the Caribbean Sea. TT is a high-income developed country with a GDP per capita of over US$20,000 and an annual GDP of US$28 billion. It has the largest economy in the English-speaking Caribbean Community (CARICOM) and is the third most populous country with 1.3 million inhabitants. An ongoing decrease in energy production and continuing decline in energy prices caused TT to enter a recession in the latter half of 2015. Economic growth will likely be depressed through 2016.
Energy exploration and production drive TT’s economy, and this sector has historically attracted the most foreign direct investment. In 2015, the energy sector accounted for approximately 32 percent of GDP and 80 percent of export earnings. TT is the world’s largest exporter of ammonia and methanol and is the sixth largest exporter of liquefied natural gas (LNG). TT has an undiversified economy and lacks economies of scale, so it depends on imports.
TT’s investment climate is generally open and most investment barriers have been eliminated. Major issues impacting companies are inefficient government bureaucracy, crime, poor work ethic in the labor force, and corruption. Some foreign investors have seen the decision-making process for tenders and the subsequent awarding of contracts turn opaque without warning, especially when their company’s interests compete with those of well-connected local firms.
Positive aspects of TT’s investment climate:
Stable, democratic political system
Educated, English-speaking workforce
Well-capitalized and profitable commercial banking system and insurance industry
Established rule of law and respect for contracts
Independent judicial system that is substantively fair
In certain sectors, lack of domestic competition
High per-capita GDP
Negative aspects of TT’s investment climate:
Widespread perception of corruption among public officials
Lack of transparency in public procurement
Inefficient and complicated government bureaucracy
Time-consuming resolution of legal conflicts
Crime, particularly violent crime, continues despite ongoing attempts to curb it
Issues to watch:
Foreign exchange shortages, which can significantly delay payment to foreign firms
November 2017 - Trinidad & Tobago: 2017 Article IV Consultation - Extract
Staff encouraged the authorities to continue progress in addressing key deficiencies outlined by the 2016 CFATF Mutual Evaluation Report (MER) on AML/CFT. The authorities have taken steps in the areas of terrorism financing, the monitoring of money remitters, and verification processes for beneficial ownership. They have also completed the National Risk Assessment, with World Bank support. Nonetheless, staff urged the authorities to move forward on remaining work, particularly to ensure the effectiveness of the AML/CFT regime.
The authorities recognized the importance of meeting international standards on tax transparency and AML/CFT, and underscored their commitment to continuing progress in these areas. The authorities agreed to give high priority to complying with the Global Forum’s standards on tax transparency, and have already laid the Mutual Administrative Assistance in Tax Matters Bill, 2017 in Parliament in April. They also acknowledged that while substantial progress has been made to improve the AML/CFT framework, work must continue, particularly on strengthening judicial processes.
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