Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Trinidad and Tobago TT

Domains (D1–D6)
1
Sources
8
Role actions
8
Horizon <90d
2
Jurisdiction profile
CompliantTier BRisk: StableMixed

AML/CFT regime rests on the Proceeds of Crime Act (POCA, Chap 11:27), Anti-Terrorism Act, FIU Act 2009, Financial Obligations Regulations 2010, Economic Sanctions Act, and new Counter-Proliferation Financing Act 2025.

MoreFIUTT is national AML/CFT Supervisory Authority for non-regulated FIs/listed businesses; TTSEC and CBTT supervise securities and banking. CFATF member undergoing 5th Round Mutual Evaluation (onsite ~Mar 2026).

Key deficiencies
  • No administrative monetary penalties regime for AML/CFT breaches across the three supervisory authorities
  • DNFBP customer due diligence historically rated Non-Compliant (R.22)
  • Targeted financial sanctions for proliferation financing (R.7) flagged Non-Compliant on current FATF country profile
  • Virtual asset/VASP sector unregulated pending comprehensive framework (expected late 2026)
  • Beneficial ownership verification relies on self-declaration plus a Companies Online Registry that FIU guidance itself states is insufficient standing alone
Recent developments (18m)
  • 3rd National ML/TF Risk Assessment (NRA) completed, public version published December 2025, coordinated by NAMLC
  • Virtual Assets and Virtual Asset Service Providers Act 2025 (Act 12 of 2025) came into force 23 December 2025, imposing a 1-year prohibition on specified VASP business activities with a TTSEC-administered Regulatory Sandbox
  • First national ML/TF/PF Risk Assessment of Virtual Assets and VASPs published March 2026
  • Counter-Proliferation Financing Act 2025 (Act No. 8 of 2025) enacted
  • Miscellaneous Provisions (FATF Compliance) Act 2025 (Act No. 7 of 2025) amended POCA confiscation-order provisions
  • POCA amended (in force 15 Aug 2025) to define virtual assets as 'property or funds' enabling seizure/freezing/confiscation
  • TTSEC opened a supervisory probe into a suspected online investment/Ponzi scheme (August 2025)
  • EU Commission reaffirmed Trinidad and Tobago's continued listing as an AML/CFT high-risk third country via Delegated Regulations (EU) 2026/46 and 2026/83 (December 2025)
  • UK MLR 2017 reg 33(1)(b)/(3)(a) amended by S.I. 2026/621 (effective 30 June 2026), abolishing the separate UK high-risk third countries list
Brief

Lead signal

Lead Signal

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Lead Signal

Trinidad and Tobago's Parliament completed affirmative-resolution passage of the Gambling (Gaming and Betting) (Remote Gambling) Order, 2026, with the Senate approving unanimously on 2 October 2026 following House approval around 30 September 2026. The development is procedural rather than substantive for AML/CFT purposes: completion of affirmative resolution does not by itself activate any reporting-entity obligation, because Part III of the Gambling (Gaming and Betting) Control Act, 2021, which contains the licensing machinery, remains unproclaimed. Once proclaimed and licences issue, remote gambling operators will become designated reporting entities subject to the Act's AML/CFT/PF risk-assessment and licensing-condition regime, a requirement already written into the primary Act text at section 30(3)(b), which requires applicants to complete a full AML/CFT/PF risk assessment questionnaire. Until proclamation occurs, that requirement sits dormant rather than operative. Government has targeted on or before 1 January 2027 for completion of the licensing framework, which is the date against which the new AML/CFT perimeter for remote gambling should be tracked.

Other Developments

Dual-regulator coordination model emerging. Convergent press reporting on ministerial statements during the Senate debate indicates that remote gambling licensing, under the Gambling Control Commission, and payment-system oversight, under the Central Bank of Trinidad and Tobago, are expected to be coordinated ahead of the targeted January 2027 rollout. This would test a dual-regulator AML supervisory model for a sector FATF treats as higher-risk, splitting licensing authority from payment-system oversight in a way that has not previously been exercised together in Trinidad and Tobago for this sector. The capacity of this dual-regulator model remains untested and the inference rests on convergence of secondary reporting rather than a primary coordination instrument.

FATF mutual evaluation schedule. Trinidad and Tobago is not on the FATF grey list, having been removed from that list in February 2020, but is scheduled for a 5th-round CFATF mutual evaluation, with a possible on-site period in March 2026 and a possible Plenary discussion in November 2026, per FATF's own global assessment calendar. The on-site window predates the current research cycle and its outcome has not been confirmed as at this writing.

VA/VASP Act 2025 architecture holds steady. The Virtual Assets and Virtual Asset Service Providers Act, 2025 (Act No. 12 of 2025), which came into effect on 23 December 2025, bars the Trinidad and Tobago Securities and Exchange Commission from granting any new VASP authorisation before 31 December 2026, routing pre-existing VASPs through a Regulatory Sandbox instead. Consequential amendments bring VASPs under the AML/CFT/CPF regime, including a travel-rule enhancement. This architecture is carried forward as standing context; no material change to it was found this cycle.

Cross-Monitor Connections

The remote gambling AML/CFT perimeter now under construction connects directly to payments-regulation tracking: the same ministerial statement that confirmed Central Bank coordination on e-money issuer licensing and a draft payment systems bill ties the gambling licensing timeline to a parallel payments-legislation track that sits primarily within payments-monitor scope. The VA/VASP Act 2025 moratorium, while stable this cycle, remains the standing backdrop against which any future crypto-adjacent gambling payment rail would need to be assessed, should such a connection emerge as the remote gambling payments environment matures.

Outlook

The single event most likely to change Trinidad and Tobago's AML/CFT exposure profile is proclamation of Part III of the 2021 Act, targeted for on or before 1 January 2027; only at that point does the dormant AML/CFT/PF risk-assessment requirement at section 30(3)(b) become operative for licence applicants. Secondary to this is the capacity test posed by the emerging dual-regulator coordination model between the Gambling Control Commission and the Central Bank, which has no track record in Trinidad and Tobago for this sector. The CFATF 5th-round mutual evaluation, with a possible Plenary discussion in November 2026, is a separate but concurrent process worth tracking alongside the gambling-sector perimeter activation, as its outcome will bear on Trinidad and Tobago's broader AML/CFT standing independent of the gambling-specific development.

weekly_brief_draft · JID TT
Domain intelligence (D1–D6)

D1 Sanctions

Not covered

Sanctions is not yet covered for this jurisdiction in this report.

D2 Beneficial Ownership

Not covered

Beneficial Ownership is not yet covered for this jurisdiction in this report.

D3 Enabler Jurisdictions

Not covered

Enabler Jurisdictions is not yet covered for this jurisdiction in this report.

D4 Conflict Finance

Not covered

Conflict Finance is not yet covered for this jurisdiction in this report.

D5 Crypto / Digital Assets / Financial Innovation

Not covered

Crypto / Digital Assets / Financial Innovation is not yet covered for this jurisdiction in this report.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

AML/CTF Regime

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Trinidad and Tobago's AML/CTF regime registered a procedural but not yet substantive development this cycle: the Gambling (Gaming and Betting) (Remote Gambling) Order, 2026 completed affirmative-resolution passage in both Houses of Parliament, the Senate approving unanimously on 2 October 2026 after House approval around 30 September 2026. The Order permits remote gambling by future licence holders under the Gambling (Gaming and Betting) Control Act, 2021, but Part III of that Act, which contains the licensing machinery, has not been proclaimed. This matters directly for AML/CTF architecture because the Act's own text, at section 30(3)(b), already requires remote gambling licence applicants to complete a full AML/CFT/PF risk assessment questionnaire before a licence can issue. That obligation exists in the statute now, but it has no reporting entities to apply to until licensing opens. The regime is therefore best described as having a designed AML/CFT perimeter with no current population inside it: the control exists on paper and will activate automatically once the first licence is granted, rather than requiring new primary legislation of its own.

A second, less certain development concerns institutional architecture rather than statute. Convergent press reporting on ministerial statements made during the Senate debate suggests that the Gambling Control Commission, which will hold licensing authority once Part III is proclaimed, and the Central Bank of Trinidad and Tobago, which is separately undertaking e-money issuer licensing work and consulting on a payment systems bill, are expected to coordinate their respective functions ahead of the targeted January 2027 rollout. If this coordination model proceeds as described, it would be a genuinely novel supervisory arrangement for Trinidad and Tobago: a FATF higher-risk sector supervised jointly by a sector regulator handling licensing and fit-and-proper assessment, and a central bank handling the payment rails through which gambling proceeds and stakes will flow. No primary coordination instrument, such as a memorandum of understanding or formal supervisory protocol between the two bodies, has been identified; the inference rests on the convergence of secondary reporting on a single Senate debate. This should be read as an emerging institutional signal rather than a settled supervisory fact, and the capacity of either body to execute a joint AML/CFT supervisory model for this specific sector is untested.

Separately, Trinidad and Tobago's broader AML/CFT standing continues on its existing track. The jurisdiction is not on the FATF grey list, having been removed in February 2020, and FATF's own global assessment calendar shows Trinidad and Tobago scheduled for a 5th-round CFATF mutual evaluation, with a possible on-site period in March 2026 and a possible Plenary discussion in November 2026. The on-site window predates this research cycle and its outcome has not yet been confirmed through any primary publication reviewed this cycle. This evaluation track runs independently of the gambling-sector development, and its result will shape Trinidad and Tobago's overall AML/CFT reputation regardless of how the remote gambling perimeter activates.

Outlook

The decisive event for this domain is proclamation of Part III of the 2021 Act, targeted by government for on or before 1 January 2027. Only at that point does the dormant section 30(3)(b) AML/CFT/PF risk-assessment requirement become operative, and only then will there be reporting entities for either the Gambling Control Commission or the Central Bank to actually supervise. Watch for any primary instrument, such as a memorandum of understanding, formalising the dual-regulator coordination model described in Senate debate, since none currently exists in the public record reviewed. The CFATF 5th-round mutual evaluation outcome, expected around a possible November 2026 Plenary discussion, is a parallel process whose result should be tracked independently of the gambling-sector perimeter, as it speaks to Trinidad and Tobago's overall AML/CFT standing rather than to the gambling sector specifically.

D8 Commercial Activity

Not covered

Commercial Activity is not yet covered for this jurisdiction in this report.

Regulatory horizon
In Force Pending2027-Q1 · ±quarter

TT Remote Gambling Order AML/CFT perimeter activation

Once proclaimed and licences issue, TT-licensed remote gambling operators become designated reporting entities subject to the Act's AML/CFT/PF risk-assessment and licensing-condition regime.
Source
In Force Pending2027-Q1 · ±quarter

VA/VASP Act 2025 moratorium expiry

After 31 Dec 2026, TTSEC may begin granting new VASP authorisations outside the current sandbox-only interim regime.
Source
2 dated · 4 pending date · baseline financial-integrity-2026-10-03
Role action cards
MLRO

TT's remote gambling AML/CFT perimeter is statutorily designed but not yet populated with any reporting entity.

Section 30(3)(b) of the 2021 Act requires an AML/CFT/PF risk assessment questionnaire from remote gambling licence applicants, but this obligation has no live reporting entities to apply to until Part III is proclaimed, targeted for on or before 1 January 2027.

2 evidence refs
Compliance

A dual-regulator coordination model between the Gambling Control Commission and the Central Bank is emerging for remote gambling payments.

Secondary reporting on Senate debate indicates the two regulators are coordinating ahead of a January 2027 rollout, but no primary coordination instrument has been identified, so the practical division of supervisory responsibility remains uncertain.

1 evidence refs
Legal

Affirmative-resolution passage of the Remote Gambling Order, 2026 does not itself create any enforceable AML/CFT obligation.

The Order permits remote gambling by future licence holders, but Part III of the 2021 Act, containing the licensing machinery, remains unproclaimed, so no licence, and therefore no reporting-entity obligation, currently exists.

1 evidence refs
Board

Trinidad and Tobago's gambling-sector AML/CFT exposure remains dormant pending a targeted 1 January 2027 licensing activation.

The legislative step has been completed but the practical AML/CFT exposure of the sector will not materialise until the parent Act's licensing provisions are proclaimed; this is the key date to track for any institution with exposure to the sector.

2 evidence refs
CTO

No material change this cycle.

No material change for this persona this cycle

Risk

An untested dual-regulator supervisory model for a FATF higher-risk sector is emerging in Trinidad and Tobago.

Splitting gambling licensing from payment-system oversight across two regulators, if it proceeds as reported, introduces a coordination risk with no precedent in Trinidad and Tobago; the capacity of either body to execute this jointly has not been demonstrated.

1 evidence refs
Operations

No material change this cycle.

No material change for this persona this cycle

Audit

A statutory AML/CFT/PF risk-assessment requirement for remote gambling exists in the Act but has not yet been operationally tested.

Section 30(3)(b)'s risk-assessment questionnaire requirement is confirmed in the primary Act text, but since no licence can yet issue, there is no current population of reporting entities against which to test control adequacy.

1 evidence refs
Decision lens
MLRO

TT's remote gambling AML/CFT perimeter is statutorily designed but not yet populated with any reporting entity.

Compliance

A dual-regulator coordination model between the Gambling Control Commission and the Central Bank is emerging for remote gambling payments.

Legal

Affirmative-resolution passage of the Remote Gambling Order, 2026 does not itself create any enforceable AML/CFT obligation.

Board

Trinidad and Tobago's gambling-sector AML/CFT exposure remains dormant pending a targeted 1 January 2027 licensing activation.

CTO

No material change this cycle.

Risk

An untested dual-regulator supervisory model for a FATF higher-risk sector is emerging in Trinidad and Tobago.

Operations

No material change this cycle.

Audit

A statutory AML/CFT/PF risk-assessment requirement for remote gambling exists in the Act but has not yet been operationally tested.

Shared evidence: 3 refs
Scenario sketches

Dual-regulator AML supervision of remote gambling payments

An illustrative pathway: as Trinidad and Tobago's remote gambling licensing framework and Central Bank payment-systems legislation mature in parallel, one plausible structural outcome is a formal supervisory split in which the Gambling Control Commission handles operator fit-and-proper and AML/CFT risk-assessment at licensing stage, while the Central Bank supervises the payment rails and e-money issuers carrying gambling-related transaction flow. This is an illustration of how such architecture could emerge from two currently separate regulatory tracks reported in Senate debate, not a description of an agreed or implemented supervisory model.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

EU AML Package / AMLA transition and cross-border obliged-entity supervision

An illustrative orientation on a structural shift unrelated to Trinidad and Tobago's own regime: as the EU AML Package moves national AML supervision toward AMLA direct and indirect supervision of cross-border obliged entities under the AMLA Regulation, alongside the directly applicable AMLR and per-state 6AMLD transposition, the supervisory and evasion landscape for entities with EU cross-border exposure could shift materially. Trinidad and Tobago sits outside this perimeter; this sketch is included as standing architecture context, not as a claim about TT's own regime.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architectureno_changeNo TT-specific or material dark-fleet, tech-procurement or commodity-rerouting signal surfaced this cycle.
T2 · EU AML Package / AMLAno_changeTT sits outside the EEA/EU AMLR-6AMLD-AMLA perimeter; no applicable movement.
T3 · FATF Grey ListwatchTT is not currently grey-listed (removed Feb 2020) but is scheduled for a 5th-round CFATF mutual evaluation, with a possible on-site period Mar 2026 and possible Plenary discussion Nov 2026.
T4 · Beneficial-Ownership Register Statusno_changeNo new TT beneficial-ownership register development surfaced this cycle.
T5 · Crypto & Digital-Asset IntegritystableTT's VA/VASP Act 2025 moratorium (no new VASP authorisation before 31 Dec 2026) and Regulatory Sandbox remain the standing architecture.
T6 · Sanctions Regime Divergenceno_changeNo TT-specific sanctions-divergence signal this cycle.
Registers

Enforcement actions

  • Under the Virtual Assets and Virtual Asset Service Providers Act 2025, a time-bound prohibition on specified VASP business activities took effect, with a TTSEC-administered Regulatory Sandbox preserving existing VASP businesses under monitored AML/CFT/CPF parameters. 23 Dec 2025
  • TTSEC initiated a probe into a company after investors who had been receiving payouts began experiencing withdrawal difficulties, consistent with a suspected Ponzi-type investment scam. 15 Aug 2025
  • FIUTT issued a circular changing the mandated time to file a Suspicious Transaction/Activity Report (STR/SAR), tightening reporting-entity compliance obligations. 6 Nov 2025
  • FIUTT issued a circular mandating a registration renewal process for all supervised entities, reinforcing the registration-compliance regime under the FIU Regulations. 5 Mar 2026

Sanctions changes

  • The European Commission adopted Delegated Regulations (EU) 2026/46 and (EU) 2026/83 amending Delegated Regulation (EU) 2016/1675, reaffirming Trinidad and Tobago's continued listing as an EU AML/CFT high-risk third country (original entry into force 6 March 2018), even though FATF itself removed Trinidad and Tobago from its own increased-monitoring list in 2020. 4 Dec 2025
  • The Council of the EU removed Trinidad and Tobago from the (separate) EU list of non-cooperative jurisdictions for tax purposes, alongside Fiji and Samoa, citing compliance with agreed international tax-transparency standards. 17 Feb 2026
  • S.I. 2026/621 amended MLR 2017 reg 33(1)(b) and (3)(a) so that mandatory enhanced due diligence under UK law now applies only to FATF call-for-action countries, abolishing the prior separate UK high-risk third countries list. Trinidad and Tobago, not being a FATF call-for-action country, carries no UK mandatory-EDD trigger under the new regime. 30 Jun 2026

Regulatory horizon (register)

  • CFATF 5th Round Mutual Evaluation onsite assessment
  • CFATF Plenary discussion of Trinidad and Tobago 5th Round MER
  • VA/VASP Act 2025 prohibition period sunset
  • Development of bespoke comprehensive VASP regulatory regime

Active schemes

  • Narco-proceeds layering via banking, MVTS and real estate
  • [HIGH] Unregulated VASP/stablecoin scam and layering pipeline
  • DPRK/Iran stablecoin sanctions-evasion exposure channel
Sources
  1. Financial Intelligence Unit of Trinidad and Tobago
  2. NAMLC / Government of the Republic of Trinidad and Tobago
  3. Financial Action Task Force (FATF)
  4. European Commission
  5. Council of the European Union
  6. NAMLC / Government of the Republic of Trinidad and Tobago
  7. Office of the Attorney General and Ministry of Legal Affairs, Trinidad and Tobago
  8. Chainalysis
Coverage gaps
Trinidad and Tobago still lacks a regulatory framework for a…
Trinidad and Tobago still lacks a regulatory framework for administrative monetary penalties for AML/CFT breaches across its three supervisory authorities (FIUTT, TTSEC, CBTT), a deficiency the 3rd NRA itself flags as needing to be cured to resolve an outstanding 4th Round Mutual Evaluation finding.
FATF's current published country profile for Trinidad and To…
FATF's current published country profile for Trinidad and Tobago records R.7 (targeted financial sanctions related to proliferation) and R.22 (DNFBP customer due diligence) as Non-Compliant, notwithstanding a 2019 follow-up report that had re-rated R.7 to Largely Compliant — indicating either a subsequent downgrade or a data-currency issue that the 5th Round MER will need to resolve.
FIUTT's own Beneficial Ownership Guidance explicitly states …
FIUTT's own Beneficial Ownership Guidance explicitly states that reliance on the Registrar General's Companies Online Registry alone does not amount to successful verification of beneficial ownership, requiring supervised entities to independently cross-check against other government databases or open-source material.
Pending the comprehensive VASP regulatory framework expected…
Pending the comprehensive VASP regulatory framework expected by late 2026, domestic VA actors are not subject to licensing, exchange-control, AML/CFT or tax obligations, and the 2026 risk assessment formally rated 'Ease of Criminality' in the sector as High.

Evidence

Confidence-tiered claims

Senate unanimously approved the Gambling (Gaming and Betting) (Remote Gambling) Order, 2026 on 2 Oct 2026 following House approval ~30 Sep 2026. SRC-fim-TT-003
Probable · 1 source
VA/VASP Act 2025 bars TTSEC from granting new VASP authorisation before 31 Dec 2026; pre-existing VASPs route through a Regulatory Sandbox; consequential amendments bring VASPs under the AML/CFT/CPF regime with a travel-rule enhancement. SRC-fim-TT-006
Confirmed · 1 source
TT is not on the FATF grey list (removed Feb 2020) and is scheduled for a 5th-round CFATF mutual evaluation, with a possible on-site period in Mar 2026 and a possible Plenary discussion in Nov 2026. SRC-fim-TT-004
Probable · 1 source
Remote gambling licence applicants under the 2021 Act must complete an AML/CFT/PF risk assessment questionnaire per s.30(3)(b). SRC-fim-TT-002
Probable · 1 source
Remote gambling licensing (Gambling Control Commission) and payment-system oversight (Central Bank) are expected to be coordinated ahead of the targeted January 2027 rollout, testing a dual-regulator AML supervisory model for a FATF higher-risk sector. SRC-fim-TT-003
Uncertain · 1 source