Trinidad and Tobago AML Obligations for Accountants: FIUTT Guidance

In Trinidad and Tobago, accountants who carry out certain activities for clients are "Listed Businesses" under the anti-money-laundering regime and are supervised by the Financial Intelligence Unit (FIUTT). This guide summarises the FIUTT's own guidance for accountants, which was last revised in February 2026, so that you can see what registration, reporting and record keeping look like in practice. For the general ideas, see our guide to KYC and customer due diligence for accountancy practices.

Where this guide comes from

We read the FIUTT's "AML/CFT/CPF Guidance for Accountants", reference GN/001/2024, version 2.1, first prepared on 23 May 2013 and last revised on 25 February 2026. It is guidance, not legal advice, and it replaces earlier accountant-sector guidance. Section and page references are to the document, and the legal references in brackets are the ones the FIUTT cites. The text we could read had some page-break artefacts, so we avoid quoting figures that looked inconsistent. This is general information, not legal advice.

Who is covered

Section 1 and section 3 of the guidance say an accountant is a Listed Business when performing specified activities for clients: buying and selling real estate; managing client money, securities or other assets; managing bank, savings or securities accounts; organising contributions for creating or operating companies; and creating, operating or managing legal persons or arrangements, including buying and selling business entities. Trust and company services, such as acting as a formation agent, nominee shareholder, director or secretary, registered office provider or express trustee, are also covered. The guidance says activities such as financial audits, and purely advisory roles where you do not direct or handle funds, are excluded, and it adds that obligations apply regardless of fees or a formal engagement letter.

Registration and the compliance officer

Registration with the FIUTT is due within thirty days of starting the business or incorporating, whichever is earlier. The certificate is valid for five years, and changes to particulars must be notified within thirty days. Failure to register is an offence. The guidance also requires a compliance officer and an alternate to be designated, each needing the FIUTT's written approval, and to be a senior employee or other competent professional.

Risk assessment and due diligence

The guidance requires a documented risk-based approach (regulation 7 of the Financial Obligations Regulations) covering geographic, client and transaction or service risk, available to the supervisor on request. It says the compliance programme should document due diligence for large transactions of TT$50,000 or higher, described as a documentation trigger rather than a stated mandatory threshold. Accountants must make sure funds come from the client and not a third party. The guidance mentions politically exposed persons only as a higher-risk client group. The beneficial owner threshold was not stated in the extract we read, so check the guidance directly.

Training and independent review

Training is required for directors and staff, covering obligations, suspicious indicators and technology risks. Independent review is required at least every three years under regulation 10, performed by a qualified independent professional, with reports to the FIUTT. Our own guide to independent AML reviews covers the UK equivalent.

Reporting suspicion

Where you know or have reasonable grounds to suspect that funds relate to criminal conduct, money laundering, terrorist financing or proliferation financing, you must report. The guidance says the report is due within fourteen days of the date the transaction was deemed suspicious (section 55A(3) of the Proceeds of Crime Act and section 22C(6) of the Anti-Terrorism Act). Attempted transactions must also be reported and the transaction or relationship discontinued. Concerns go first to the compliance officer, who decides on filing. For terrorist funds, clients are screened against the UN lists and the national consolidated list at onboarding and on notice of updates, and a match is reported immediately. Property linked to listed entities under the DPRK and Iran orders is reported immediately after the list is circulated.

Records and penalties

Records must be kept for six years, in electronic or written form (regulation 31). On penalties, the guidance cites section 57 of the Proceeds of Crime Act and regulation 42: on summary conviction, a fine of up to $2 million and up to two years in prison, and on indictment a fine of up to $5 million and up to seven years. Similar structures apply under the Anti-Terrorism Act. The guidance also lists administrative fines for failures to register or notify changes but says they are reserved for exceptional cases. Dollar amounts are as printed in the guidance. Our guide to suspicious activity reports and tipping off explains why reporting discipline matters.

Practical steps (our suggestions)

• Check each engagement against the activity list, and note which fall under the exclusions.
• Register with the FIUTT within thirty days of starting out, and diarise the five-year renewal.
• Put the fourteen-day reporting window and the immediate terrorist funds route in your procedures.
• Schedule the independent review at least every three years.
• Keep your team current. Our CPD courses include financial crime topics.

What we could not confirm

The extract we read did not state the beneficial owner threshold or how the guidance treats tipping off, and some footnotes and linked documents were not captured. The extract also had inconsistent details about the administrative fines and the FIUTT Regulations penalties, so we have not repeated those figures. We did not read the statutes or the Financial Obligations Regulations themselves. Check the FIUTT website for the current version before relying on this guide.

Frequently asked questions

Is an accountant always a Listed Business?

No. According to the guidance, only when performing the specified activities for clients, and not for activities such as financial audits.

How quickly must a suspicious transaction be reported?

Within fourteen days of the date the transaction was deemed suspicious.

How long must records be kept?

Six years, under regulation 31.

How often is an independent review needed?

At least every three years under regulation 10.

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