Model Compliance Programme for Accountants.doc

Reasonable grounds to believe that a customer has

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reasonable grounds to believe that a customer has funds in Trinidad and Tobago, the following immediate action must be taken: i. Orally, via telephone inform the FIU ii. Complete the Terrorist Funds Report (refer to Appendix V) iii. Submit the completed form electronically, by the secure reporting system established by the FIU or alternatively iv. Submit the completed form in hard copy by hand in a sealed envelope (e) If the customer attempts to enter into a transaction or continue the business relationship , I/Entity XXX : Page | 20
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i. Must not enter into or continue the business transaction or the business relationship; and ii. Must submit a Suspicious Transaction / Activity Report to the FIU Under no circumstances should I/Entity XXX enter into or continue a business transaction or business relationship with a customer who is included in the above Lists. Page | 21
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7. Acceptance of Funds from Customers 7.1 All invoices issued by me/Entity XXX must be addressed to the client as follows: If a company - to its registered office address If an individual – to the address indicated on a recent utility bill in the client’s name If a partnership – to the address indicated on a recent utility bill either in the client’s name, or failing this, in the name of one of the Partners of the client. 7.2 In the following circumstances, the source of the funds must be determined from the client and documented: For amounts received from customers to conduct the relevant business activities on their behalf (as per Section 2.2) – the source of funds must be determined in all instances. If the customer was determined to be high risk (at the onset of the relationship), then further/ enhanced due diligence procedures must be conducted e.g. the verification of the source of the funds For professional services rendered - Any one-off or occasional amounts received in the amount of TT$ 90,000.00 or two or more one-off amounts received each of which may be less than $90,000.00 but together value $90,000.00 or more Any one off or occasional wire transfer in the amount of TT$6,000.00 or two or more one-off transactions each of which may be less than $6,000.00 but together value $6,000.00 or more We will not accept cash receipts over $XXXXX Clients will be required to declare the source of funds at the time of making the payment to the entity which could be captured by the use of a Source of Funds Declaration Form, an example of which is included in Appendix III. 8 Record Keeping Page | 22
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8.1 Records of client and transaction data must be kept for at least 6 years and or at least 6 years after relationship ends. 8.2 Where a suspicious transaction was reported or where investigations are ongoing, the FIU may advise of a longer period for the relevant supporting documentation to be maintained. 8.3 Staff records must be maintained for a period of six (6) years from the date of termination. The data to be maintained must include: name and addresses, position titles and other official staff information .
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