AML for Attorney-at-Law – Online
September 7th, 2021 | Related To: NEM Leadership Consultants
The Financial Intelligence Unit of Trinidad and Tobago (FIUTT) has provided Guidance with respect to Attorneys-at-Law obligations under the Anti-Money Laundering/Counter Financing of Terrorism (AML/CFT) regime of Trinidad and Tobago.
In accordance with the FIUTT Guidance, if you are a sole practitioner or firm or partnership, you are subject to the AML/CFT obligations only if you perform the following specified activities on behalf of any individual or entity (other than your employer):
- Buying and selling of real estate property
- Managing of client’s money, securities and other assets
- Management of banking, savings or securities accounts
- Organisation of contributions for the creation, operation or management of companies, legal persons or arrangements, and
- Creation, operation or management of companies, legal persons or arrangements, and buying or selling of business entities.
Under Schedule 1 (Listed Businesses) of the Proceeds of Crime Act, Chap: 11:27 (“the POCA”), Attorney-at Law is listed as a reporting entity. Reporting entities are required to establish systems of controls to deter and detect money laundering and financing of terrorism activities.
Some of the AML/CFT obligations for Attorney – at- Law are:
• Need to register the FIUTT
• Report Suspicious Activities to the FIUTT
• Develop a Compliance Programme
• Appoint a Compliance Officer and Alternate Compliance Officer
• Maintain Records
• Determine Client Identity
• Train Staff and Attorneys within the form or Chamber
These obligations apply to you if you are an Attorney-at-Law admitted to practise law in Trinidad and Tobago when you perform the activities as listed above. It does not apply to Attorneys-at-Law employed by a public authority or in-house counsel.
The FIUTT specified that if you are an employee of a sole practitioner or firm or partnership, these requirements are the responsibility of your employer but you as an employee will have internal reporting of suspicious transactions and terrorist property obligations in accordance with your employer’s compliance programme.
For more information on the Attorney-at law obligations and to fulfil your requirements, go to