League of Trinidad and Tobago, CULTT, continues it thrust to ensure that credit unions remain abreast of all requirements as is required under, inter alia, the Proceed of Crime Act, the Anti-Terrorism Act and the Financial Obligation Regulations.
In this regard, our education thrust continues with adequate focus on training and retraining of all credit union leaders, management and staff. In this connection, we continue to partner with the Financial Intelligence Unit of Trinidad and Tobago (FIUTT) and are an integral part of its Stakeholders Committee that meets on a quarterly basis.
Our ongoing good collaboration with the FIUTT is a testimony of the League’s determination to ensure compliance of our member credit unions. The FIUTT’s Annual Report, page 55 confirms the strengthening of this partnership. More importantly, at the invitation of the FIUTT, the League, through its Chief Operating Officer, Ms Dianne Joseph, delivered an address to a large group of Compliance Officers on September 04, 2013 and treated with the topic of ‘Compliance from a Small Business Perspective’.
This intervention demonstrates to a larger extent, the League’s commitment to not only support the work of credit unions, but that of all small business which falls under the grouping of ‘Supervised Entities’.
The 2013 Annual Report of the FIUTT also provides good analytical reporting and highlights on pages 28 and 29 of said report that, 87% of the Supervised Entities’ Suspicious Transaction Reports (STR)/Suspicious Activities Reports (SAR) for 2013 came from the Money/Value Sector (MVS), with other supervised entities accounting for 13%. Included in the 13% are co-operative societies which accounted for 5%. In the Financial Institutions Category, the Banking Sector continues to file the largest number of STRs/SARs, having accounted for 79%. Other sectors which include Insurance, Mutual Funds, Securities Dealer, Exchange Bureaux and Mortgage Companies account for 21%.
The FIUTTs Annual Report on page 22 clarifies that while there was an increase in STRs/SARs in the MVS for the reporting period, the corresponding dollar value was low and cities further guidance as one of the ways to attaining a better quality of these reports. The reports from the financial institutions continue to be of a high quality, the FIUTT stated.
The League wishes to point out that the submission of STRs/SARs does not in any way indicate that a supervised entity or financial institution is vulnerable to Money Laundering/Terrorist Financing. It may simply mean that the organization is keeping abreast of the rules and regulations and has a low tolerance on potential risks.
In an effort to guide the process for our members, the League designs and implements training interventions based on members’ needs – This with the aim of ensuring that our leaders are well equipped to lead effectively; and of course, are in compliance with the Laws and Regulations.
We encourage our Members to establish and maintain sound compliance risk policies, procedures and internal controls based on risk assessments of the organization and maintain that a strong compliance and reputational risk management programme includes, employees meeting acceptable standards for doing business and should also include a mechanism to ensure critical review of high risk transactions. We emphasize however, that zero risk does not exist for organizations and should not be a goal.
As a responsible Parent Body, and in order to assist our credit unions in all categories, the League implemented a Shared Services Platform as part of its structure and this has been having phenomenal success to date. This department is staffed with Compliance expertise and is responsible for the external testing, development of Compliance Programmes, annual training of all board/committees/staff and annual compliance audits, among others.
The oversight is rigid, the education thrust consistent and members are becoming more and more aware of the need to comply with the Law. And, while credit unions are not considered immune to becoming a target of Money Launderers or those who finance terrorism, our systems and structures will make it very difficult for those involved in such misdeeds to be successful. The CCULTT is confident that at this present time, there are no increases in suspicious moves within the Cooperative Credit Union Sector since we are well involved with the FIUTT in ensuring that the financial operations of all our member units are compliant with the requirements of the Laws governing such suspicious transactions/activities.
You are invited to contact 671/4704 to talk with us on our Compliance thrust as we work together to counter Money Laundering and Terrorist Financing in our lovely twin-island state.
