Circular Letter – Process of Approval of Compliance Officer-Dual Entities

Trinidad and Tobago Securities and Exchange Commission __________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ LEVELS 22-23, TOWER D, INTERNATIONAL WATERFRONT CENTRE, 1 WRIGHTSON ROAD, PORT OF SPAIN, TRINIDAD, W.I. Tel: (868) 624-2991 | Email: ttsec@ttsec.org.tt | Website: www.ttsec.org.tt TTSEC-C&I-23389-NJ-25/11/2024 November 25, 2024 This Circular Letter replaces previously issued Circular Letter dated June 1, 2020, Ref TTSEC-C&I-16205-RK-29/5/2020 CIRCULAR LETTER ISSUED TO:
BROKER-DEALERS,
UNDERWRITERS,
INVESTMENT ADVISERS
REGISTERED UNDER SECTION 51(1) OF THE SECURITIES ACT, CHAP 83:02 APPROVAL OF THE COMPLIANCE OFFICER AND THE DESIGNATION AND/OR APPROVAL OF THE ALTERNATE COMPLIANCE OFFICER FOR FINANCIAL INSTITUTIONS REGULATED BY MORE THAN ONE SUPERVISORY AUTHORITY The Trinidad and Tobago Securities and Exchange Commission (“the Commission”) refers to Regulation 4(2) of the Financial Obligations Regulations 2010 (as amended) (“FOR”) and Guidelines 6(8), (9) and (10) of the Commission’s Anti-Money Laundering and Counter Financing of Terrorism (“AML/CFT”) Guidelines for the Securities Sector regarding the approval of the Compliance Officer. Reference is also made to Regulation 3(9) and Regulation 3(11) of the FOR in respect of the designation and where applicable, the approval of the alternate Compliance Officers. This notification is issued to advise registrants of the process to be followed when submitting applications for approval of the Compliance Officer and designation and/or approval of the alternate Compliance Officer for registrants regulated by more than one Supervisory Authority. In instances where a registrant is regulated by more than one Supervisory Authority, the registrant must:

1. Submit simultaneously to each relevant Supervisory Authority (see Appendix 1):
   a. applications for approval of the Compliance Officer in accordance with Regulation 4(2) of the FOR; b. notifications of the designation of an alternate Compliance Officer in accordance with Regulation 3(9) of the FOR; or
   c. applications for approval of an alternate Compliance Officer in accordance with Regulation
   3(11) of the FOR.

Trinidad and Tobago Securities and Exchange Commission __________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ LEVELS 22-23, TOWER D, INTERNATIONAL WATERFRONT CENTRE, 1 WRIGHTSON ROAD, PORT OF SPAIN, TRINIDAD, W.I. Tel: (868) 624-2991 | Email: ttsec@ttsec.org.tt | Website: www.ttsec.org.tt
2. Ensure that the Compliance Officer satisfies the requirements outlined in the Commission’s Fit and
Proper Criteria, which may be found on the Commission’s website https://www.ttsec.org.tt/aml-cft/fit￾proper-criteria-for-approval-of-compliance-officers/
3. Submit the required documentation of each Supervisory Authority, some of which are:
i. Fully completed and duly certified form as required by each applicable Supervisory
Authority i.e. Application Form for the Approval of Compliance Officers, Personal Questionnaire and Declaration Form, or Compliance Officer Fit and Proper Questionnaire, where applicable;
ii. Certified copies of academic certificates (Bachelor’s Degree or higher),
AML/CFT/CPF-relevant certifications, professional qualifications and membership certificates.
iii. Up to date and signed Curriculum Vitae detailing the employment history of the
Applicant;
iv. Certified coloured copies of two valid forms of identification for the Applicant;
v. Two (2) coloured Passport sizes Photos;
vi. Certificate of Character from the Trinidad and Tobago Police Service (TTPS) issued
within 6 months; and
vii. Any other documentation, as required by the relevant Supervisory Authority.
4. Ensure that the application meets the required Fit and Proper Criteria and all other required
documentation is submitted within seven (7) working daysfollowing the selection of the Compliance Officer by the registrant, to each relevant Supervisory Authority. Please be guided accordingly and we look forward to your continued co-operation and timely submissions. Yours Sincerely, ______________________ Kester Guy Chief Executive Officer

Trinidad and Tobago Securities and Exchange Commission __________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ LEVELS 22-23, TOWER D, INTERNATIONAL WATERFRONT CENTRE, 1 WRIGHTSON ROAD, PORT OF SPAIN, TRINIDAD, W.I. Tel: (868) 624-2991 | Email: ttsec@ttsec.org.tt | Website: www.ttsec.org.tt
APPENDIX I - DESIGNATED EMAIL CONTACT

1. CENTRAL BANK OF TRINIDAD AND TOBAGO
   Email: aml@central-bank.org.tt
2. TRINIDAD AND TOBAGO SECURITIES AND EXCHANGE COMMISSION
   Email: aml@ttsec.org.tt
3. FINANCIAL INTELLIGENCE UNIT OF TRINIDAD AND TOBAGO
   Email: fiucompliance@gov.tt