Money Laundering Basics
What are the three main stages of money laundering?
What are Placement, Layering, and Integration
The member refuses to provide identification or proof of address.
What type of red flag is this?
What is a KYC refusal red flag
What does the acronym FIUTT stand for
What is the Financial Intelligence Unit of Trinidad and Tobago?
A teller notices a member making multiple deposits just under TT$50,000 but doesn’t report it.
What is failure to recognize structuring and file an ISAR?
Staff member fails to report suspicious activity.
What is non-compliance with internal escalation procedures?
During which stage of money laundering is cash from illegal activity first introduced into the financial system
What is the Placement stage
A long-time member suddenly changes their contact information and becomes defensive when questioned about large deposits.
What is a behavioral change indicating potential ML?
Which law in Trinidad & Tobago outlines the offences and obligations related to money laundering?
What is the Proceeds of Crime Act (POCA)
Staff detect unusual third-party payments but delay reporting until month-end because “no crime has been proven.”
What is the misunderstanding of the ISAR trigger — suspicion, not proof?
Compliance reviews show missing member KYC forms.
What is a deficiency in recordkeeping?
In the credit union sector, which stage of money laundering is often associated with deposits large cash amounts, then transfers funds between several internal accounts
What is the Layering stage
A new member provides inconsistent information about their job and source of funds
What is a due diligence inconsistency?
Under AML/CFT laws, to which authority must a Suspicious Transaction Report (STR) be filed?
What is the Financial Intelligence Unit of Trinidad and Tobago (FIUTT)?
A member becomes angry when asked about the source of funds and insists, “You people don’t need to know that.”
What is refusal to provide source-of-funds information?
Same officer opens accounts for multiple high-risk members with minimal checks.
What is collusion or negligence risk?
What is the final stage of money laundering called, where illicit funds are reintroduced into the economy as apparently legitimate assets
What is Integration
The member says, “Don’t worry, this money is clean — I just need to move it fast.”
What is a suspicious intent?
Under the POCA, what offence occurs when an employee informs a member that they are being investigated or reported for suspicious activity?
What is the offence of Tipping Off?
A suspicious pattern is identified by the Transaction Monitoring System, but the branch never escalates it because “the member is a community leader.”
What is failure to act due to bias or influence?
The branch’s STR filings decrease significantly, even though cash deposits are increasing.
What is a red flag of weak reporting culture or poor detection systems?
A Member takes a legitimate loan and then repays it early using large cash amounts that exceed their declared income.
At which stages of money laundering could the activity occur
What is Placement
What are the two essential documents typically required for individual CDD?
What is a valid form of identification (e.g., passport or ID card) and proof of address (e.g., utility bill, bank statement)?
Which laws empower FIUTT to request information or conduct inspections on real estate agents?
What is the Financial Intelligence Unit of Trinidad and Tobago Act
True or False: An ISAR should only be filed if a transaction is completed.
What is False? STRs must be filed even if the transaction is only attempted
The Compliance Officer identifies recurring breaches across several branches but notices no disciplinary action or reporting to the Board.
What is failure of escalation and governance oversight?