For the regular person, online trading accounts will be halted. West said: “When we were on the enhanced monitoring list, there were citizens in this country whose online trading accounts had been stopped. Also, citizens travelling abroad may not have the privilege of using credit cards from local banks. You may go to a country, hand them a card from one of Trinidad’s banks and they will simply say, sorry sir/ma’am but we do not accept cards from that institution.”
 
‘Politically Exposed Persons’
On the issue of PEPS, people identified as belonging to this category should be automatically red-flagged by financial institutions when conducting large or “risk” transactions. This is recommendation 12 of the FATF’s International Standards on Combating Money Laundering and the financing of terrorism and Proliferation, February 2012. There are two categories of PEPs—Foreign PEPs and domestic PEPs.

• The foreign PEPs according to FATF “are individuals who are or have been entrusted with prominent public functions by a foreign country, for example Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations and important political party officials.”

Originally the recommendations to monitor PEPs were directed at this group, however, under the new 40 recommendations of the FATF, domestic PEPs were included in the list of people to be monitored.

• Domestic PEPs according to the FATF document are “individuals who are or have been entrusted domestically with prominent public functions, for example Heads of State or of government, senior politicians, senior government officials, judicial or military officials, senior executives of state owned corporations and important political party officials.”

Also people who are or have been entrusted with a prominent function by an international organisation like members of senior management, ie directors, deputy directors and members of the board or equivalent functions are also included. Also included are family members and close associates to those mentioned above.

According to the document “financial institutions should be required to take reasonable measures to determine whether a customer or beneficial owner is a domestic PEP and in cases of higher risk business should take particular care before embarking on business with such people.

According to the document, having determined that the customer is a PEP, bank officials “must obtain senior management approval before establishing or continuing such business relationships and must take reasonable measures to establish the source of wealth and source of funds and conduct enhanced ongoing monitoring of the business relationship.” The issue of PEPs and Trinidad’s refusal to heed the FATF’s recommendations will also be factored into next year’s assessment.