United Nations’ Security Council 1718 & 2231 sanctions lists

In January, 2019 the Ministry of the Attorney General & Legal Affairs was successful in securing Orders from the High Court of Justice in respect of 80 individuals and 75 entities listed on the United Nations’ Security Council 1718 Sanctions List and 23 individuals and 61 entities listed on the United Nations’ Security Council 2231 Sanctions List, declaring those individuals listed entities and freezing their funds pursuant to the Economic Sanctions (Implementation of United Nations Resolutions on The Democratic People's Republic of Korea) Order, 2018 and the Economic Sanctions (Implementation of United Nations Resolutions on The Islamic Republic of Iran) Order, 2018. These two pieces of subsidiary legislation were enacted on December 14, 2018 by Her Excellency the President in accordance with the Economic Sanctions Act, Chap. 81:05.

The effect of these Court Orders requires that financial institutions and listed businesses immediately notify the Financial Intelligence Unit of Trinidad and Tobago (the FIUTT) if any listed entity has funds with the financial institution or listed business in Trinidad and Tobago and further, immediately file a suspicious activity report with the FIUTT if the listed entity attempts to enter into a transaction or continue a business relationship. The financial institution or listed business is also obliged not to proceed with such transaction or continue such relationship and further to continuously monitor all listed entities. These are among the State’s strategic measures to inhibit listed entities involved in the proliferation of weapons of mass destruction from accessing, raising, moving and using funds in our domestic financial market thereby protecting the integrity and enhancing the transparency and accountability of Trinidad and Tobago’s financial system in the fight against proliferation financing and by extension, the global financial network.

This addresses another key deficiency in our country’s compliance with obligations under the United Nations regimes as well as the Financial Action Task Force (FATF) to implement targeted financial sanctions (TFS) to comply with respective United Nations Security Council Resolutions relating to the prevention, suppression and disruption of proliferation of weapons of mass destruction and its financing. Trinidad and Tobago continues to work diligently to ensure TFS are implemented without delay and to address all identified deficiencies in our AML/CFT framework and to keep pace with new international AML/CFT norms. These Court orders are a milestone in achieving our country’s commitments in the FATF International Cooperation Review Group Action Plan and taking us closer to being removed from the FATF Compliance Document.

These two pieces of subsidiary legislation and the Court Orders serves to protect all citizens of Trinidad and Tobago from fear, intimidation and physical harm caused by weapons of mass destruction by introducing measures relating to the prevention, suppression and disruption of proliferation of weapons of mass destruction and its financing in the global financial system. These Orders also demonstrate the full commitment of the Government and people of Trinidad and Tobago to working with all members of the Global Community, within an established framework of international law, to achieve international peace and security.

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