Over the past two months, T&T has made sig­nif­i­cant strides in achiev­ing com­pli­ance with in­ter­na­tion­al stan­dards re­gard­ing an­ti-mon­ey laun­der­ing (AML) prac­tices.

T&T was of­fi­cial­ly re­moved from the EU list of non-co­op­er­a­tive tax ju­ris­dic­tions, fol­low­ing a de­ci­sion by the Eu­ro­pean Union’s Eco­nom­ic and Fi­nan­cial Af­fairs Coun­cil on Feb­ru­ary 17.

Two weeks lat­er, all 36 mem­bers of Par­lia­ment present dur­ing a sit­ting of the House vot­ed in favour of amend­ments to the Mis­cel­la­neous Pro­vi­sions (FATF Com­pli­ance) Bill, 2026.

The bill sought to strength­en leg­is­la­tion that ad­dressed an­ti-mon­ey laun­der­ing, counter-ter­ror­ism fi­nanc­ing, and reg­u­la­to­ry over­sight, all of which had been iden­ti­fied as cru­cial un­der the Fi­nan­cial Ac­tion Task Force (FATF) com­pli­ance frame­work.

How­ev­er, for­mer Min­is­ter in the Min­istry of Fi­nance Con­rad Enill said that, de­spite signs of progress from a leg­isla­tive stand­point, T&T and the Caribbean must ad­dress their cul­ture with re­gard to an­ti-mon­ey laun­der­ing.

“Clear con­sen­sus has emerged that the Fi­nan­cial Ac­tion Task Force has em­pha­sised that ef­fec­tive AML frame­works de­pend not on­ly on rules and sys­tems but on the cul­ture with­in in­sti­tu­tions that gov­ern how these rules are ap­plied,” said Enill at the Caribbean An­ti-Mon­ey Laun­der­ing Hy­brid Con­fer­ence 2026 at the Radis­son Ho­tel in Port-of-Spain.

Enill, who is a past Gov­er­nor of both the In­ter­na­tion­al Mon­e­tary Fund and the World Bank and has al­so served as Gov­er­nor of the In­ter­na­tion­al Fi­nance Cor­po­ra­tion, re­ferred to stances tak­en by these or­gan­i­sa­tions to fur­ther dri­ve home the point, as he stat­ed, “The Bank for In­ter­na­tion­al Set­tle­ments has re­in­forced that gov­er­nance and in­sti­tu­tion­al be­hav­iour are cen­tral to man­ag­ing risk. And the In­ter­na­tion­al Mon­e­tary Fund has shown that fi­nan­cial fail­ures are rarely caused by a lack of reg­u­la­tion, but by fail­ures in be­hav­iour and de­ci­sion mak­ing.”

He ex­plained that while poli­cies had been es­tab­lished, with­out the will to act when breach­es are iden­ti­fied, the Caribbean re­gion could once again be deemed non-com­pli­ant.

“Are we build­ing com­pli­ant in­sti­tu­tions or com­pli­ant cul­tures? Be­cause in to­day’s en­vi­ron­ment, com­pli­ance is no longer de­fined by what is writ­ten in pol­i­cy, but by what is prac­tised in cul­ture,” he said at the event.

He said that while com­pli­ance is tra­di­tion­al­ly pol­i­cy-dri­ven and spear­head­ed by a spe­cif­ic de­part­ment, glob­al stan­dards have evolved as a re­sult of the de­mands of the Fi­nan­cial Ac­tion Task Force.

He ex­plained that ef­fec­tive­ness is now be­ing em­pha­sised.

“This, there­fore, re­quires a shift from sta­t­ic frame­works and pe­ri­od­ic au­dits to con­tin­u­ous mon­i­tor­ing, em­bed­ded be­hav­iours, and risk-based think­ing. Com­pli­ance must there­fore live with­in the DNA of the or­gan­i­sa­tion, not sit along­side it,” Enill ex­plained, not­ing that this is due to the fact that crim­i­nals have al­so evolved their ap­proach, and as such, there is a need for sim­i­lar adap­ta­tion on the oth­er side.

“What is the new re­al­i­ty? The new risk re­al­i­ty we are now op­er­at­ing in a dif­fer­ent en­vi­ron­ment that con­sists of dig­i­tal­ly en­abled fi­nan­cial crime, cross-bor­der fi­nan­cial sys­tems, vir­tu­al as­sets, and high-speed trans­ac­tions. The Bank for In­ter­na­tion­al Set­tle­ments have warned, and fi­nan­cial crime is evolv­ing faster than in­sti­tu­tion­al con­trols,” said Enill.

“Crim­i­nals are adap­tive, da­ta-dri­ven, glob­al­ly con­nect­ed, which means the speed of fi­nan­cial crime is now out­pac­ing tra­di­tion­al com­pli­ance meth­ods.”

For the poli­cies to work, he said, a cul­ture of ac­tion when ir­reg­u­lar­i­ties are iden­ti­fied must be­come the norm.

He ex­plained, “Cul­ture comes in­to sharp fo­cus be­cause cul­ture is where fail­ure ac­tu­al­ly oc­curs. Com­pli­ance fail­ures do not oc­cur in pol­i­cy doc­u­ments. They oc­cur in mo­ments.

“A trans­ac­tion is flagged—the sys­tem works. The alert is gen­er­at­ed, but its de­ci­sion is not es­ca­lat­ed. That is not a sys­tem fail­ure; that is a cul­tur­al fail­ure, and glob­al ex­pe­ri­ence con­cludes this. Re­views by the In­ter­na­tion­al Mon­e­tary Fund and the Bank for In­ter­na­tion­al Set­tle­ments show that sys­tems do not fail on pa­per; they fail in prac­tice.”

Enill pre­sent­ed a frame­work to the au­di­ence, which he de­scribed as a strate­gic mod­el that could guide lo­cal and re­gion­al com­pa­nies in achiev­ing com­pli­ance.

“This is not a sub­sti­tute for FATF stan­dards, su­per­vi­so­ry frame­works or in­sti­tu­tion­al com­pli­ance pro­grammes. Those are es­sen­tial. This one is dif­fer­ent. It is a strate­gic lens to un­der­stand the con­di­tions un­der which com­pli­ance frame­works suc­ceed,” said Enill, who ex­plained that his frame­work held sim­i­lar­i­ties to those prac­tised in the In­ter­na­tion­al Mon­e­tary Fund, and as­sess­ments utilised by the US De­part­ment of Jus­tice com­pli­ance eval­u­a­tions.

“You will see re­cur­ring themes. You will see lead­er­ship, risk, aware­ness, be­hav­iour, ac­count­abil­i­ty, re­sources, and mea­sure­ment. What this mod­el does is syn­the­sise those prin­ci­ples in­to in­struc­tions that lead­ers can use to guide in­sti­tu­tions strate­gi­cal­ly,” said Enill, who then list­ed five strate­gic pil­lars re­quired for suc­cess in AML com­pli­ance.

“One: lead­er­ship own­er­ship. Boards must own com­pli­ance. Risk ap­petite must be clear. Be­hav­iour must be mod­elled from the top.

“Two: em­bed­ded be­hav­iour. Com­pli­ance must in­flu­ence de­ci­sions, maybe con­sis­tent­ly; if be­hav­iour does not change, cul­ture does not ex­ist. Three: aligned in­cen­tives, we know what gets re­ward­ed gets done. Re­ward in­tegri­ty, sanc­tion si­lence,” said Enill.

He con­tin­ued, “Tech­nol­o­gy in­te­gra­tion: an­oth­er pil­lar. AI and sys­tems must de­tect, sup­port, and en­able re­al-time ac­tion, but al­ways with­in gov­er­nance. And, of course, five: mea­sure­ment and ac­count­abil­i­ty. Cul­ture must be tracked in terms of be­hav­iour, re­port­ing qual­i­ty, and re­sponse time. What is not mea­sured is not sus­tained.”

Enill said the ap­proach has to be­gin with boards and se­nior man­age­ment, as they of­ten dic­tate the cul­ture of the or­gan­i­sa­tion, and while he ac­knowl­edged tech­nol­o­gy could help—with AI and com­pli­ance sys­tems aid­ing in spot­ting risks—he again stressed this could be un­der­mined.

“Re­mem­ber, tech­nol­o­gy am­pli­fies cul­ture. It does not re­place it. Cross-bor­der chal­lenges. Then we come to cross-bor­der com­pa­nies, where cul­ture is test­ed across ju­ris­dic­tions. Then cor­re­spond­ing bank­ing re­la­tion­ships, where cul­ture be­comes cred­i­bil­i­ty, es­pe­cial­ly in the Caribbean con­text. Then Fin­Tech and vir­tu­al as­sets, where cul­ture must be de­signed, not in­her­it­ed,” said Enill, who not­ed that the re­gion’s rep­u­ta­tion must be pro­tect­ed through the adop­tion of the right ap­proach to AML.

He said, “For the Caribbean, this is crit­i­cal. The Caribbean Fi­nan­cial Ac­tion Task Force em­pha­sis­es ef­fec­tive­ness. And in our re­gion, cor­re­spon­dent bank­ing is frag­ile. Rep­u­ta­tion­al risk is im­me­di­ate. One fail­ure can have sys­temic con­se­quences.”

Enill urged, “If you are a board mem­ber, own com­pli­ance. If you are a com­pli­ance of­fi­cer, chal­lenge as­sump­tions. If you are a reg­u­la­tor, mea­sure cul­ture; if you are part of the sys­tem, take re­spon­si­bil­i­ty. Across the glob­al sys­tem, from the Fi­nan­cial Ac­tion Task Force to the In­ter­na­tion­al Mon­e­tary Fund, one con­clu­sion is clear: com­pli­ance cul­ture de­ter­mines in­sti­tu­tion­al sur­vival.”

The for­mer fi­nance min­is­ter stressed that mak­ing the right de­ci­sions con­sis­tent­ly with­in this frame­work is nec­es­sary to up­hold the Caribbean’s rep­u­ta­tion in the glob­al land­scape.