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Last updated · 14 modules · 76 sourced findings · 132 sources in the cumulative register

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Jurisdiction brief

Latest update · 11 October 2026

Lead Signal

Trinidad and Tobago's payments environment moved on two fronts this cycle. The Central Bank's public consultation on the draft Payment Systems and Services (PSS) Bill and accompanying regulations closed on 20 June 2026, with the draft introducing a regulatory sandbox, simplified licensing, enhanced interoperability requirements, and an alternative dispute resolution mechanism for payment complaints. Separately, government ministers stated during Senate debate on the Remote Gambling Order that oversight of gambling-sector payment flows will run through the existing competent authorities, specifically the Gambling Control Commission and the Central Bank, linking the gambling liberalisation reform directly to the Central Bank's payment-licensing architecture.

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Trinidad and Tobago has no single unified PSP/EMI licensing statute; payments oversight is exercised by the Central Bank of Trinidad and Tobago (CBTT) under the Central Bank Act Chap 79:02 (s.36(cc)) and the Financial Institutions Act Chap 79:09 (FIA), supplemented by Payment Systems Guidelines and the E-Money Issuer Order 2020 (as amended 2023). A modern Payment Systems and Services Bill to consolidate and expand CBTT's licensing/enforcement powers is in public consultation and expected to be laid in Parliament in September 2026.

Standing sub-brief · as of 4 October 2026409 words · last cycle 2026-10-11

Licensing, Authorisation & Market Access

Trinidad and Tobago's payment-licensing environment acquired a new, explicit dependency this cycle. The Minister of Planning told the Senate that the Central Bank of Trinidad and Tobago has already undertaken work on licensing electronic money issuance and launched public consultation concerning proposed payment systems, specifically as part of the regulatory environment being built for remote-gambling payments ahead of a targeted January 2027 rollout. This is a material development because it is the first statement to tie the Central Bank's existing payments-licensing machinery and its draft legislative reform directly to a specific sectoral launch date, rather than treating payments reform as a self-contained domestic workstream.

Periodic update · new data 2026-10-11

Licensing, Authorisation & Market Access

The Central Bank of Trinidad and Tobago's public consultation on the draft Payment Systems and Services (PSS) Bill and accompanying regulations closed on 20 June 2026. The draft bill, as described by the Central Bank, introduces a regulatory sandbox for payment innovation, simplified licensing procedures, enhanced interoperability requirements across payment systems, and an alternative dispute resolution mechanism for payment complaints. The bill has not yet been enacted. Separately, in connection with the Remote Gambling Order reform moving through the Senate, government ministers stated that oversight of gambling-sector payment flows will run through the existing competent authorities, specifically the Gambling Control Commission and the Central Bank. This statement ties a sector-specific liberalisation reform directly to the Central Bank's existing and developing payment-licensing architecture, though it was reported through a single press account of a ministerial statement rather than an official Hansard transcript or regulatory publication.

The licensing and market-access picture in Trinidad and Tobago is therefore in a state of transition: the existing licensing architecture administered by the Central Bank continues to operate, while the draft PSS Bill, if enacted, would introduce a materially simplified and sandboxed route for new entrants, and the gambling sector's payment oversight has been stated as running through the same Central Bank architecture once the gambling reform's framework becomes operational.

Outlook

Whether and when the draft PSS Bill is enacted following the close of its consultation on 20 June 2026 is the principal licensing-and-market-access item to watch. No enactment date has been confirmed. The interaction between the bill's proposed sandbox and simplified-licensing provisions and the gambling sector's stated payment-oversight architecture is a further point to watch, as the two reforms are proceeding on separate but potentially converging timelines.

Sources and findings (8)
  1. T1https://www.central-bank.org.tt/registration-payment-service-providers-bill-payment-service-providers-and/retrieved
  2. T1https://www.central-bank.org.tt/fintech-and-payments/payment-services/retrieved
  3. T1https://www.central-bank.org.tt/fintech-and-payments/payment-system-landscape/retrieved
  4. T1https://foreign.gov.tt/documents/1391/E-Money_-_LN2023_391_240130_095235.pdfretrieved
  5. T1https://www.elibrary.imf.org/view/journals/002/2023/322/article-A001-en.xmlretrieved
  6. T1https://www.central-bank.org.tt/fintech-and-payments/payment-services/retrieved
  7. T3https://www.ttt.live/public-consultations-continue-on-draft-payment-systems-and-services-bill/retrieved
  8. T1https://www.central-bank.org.tt/central-bank-registers-gracekennedy-trinidad-tobago-limited-as-a-payment-service-provider-in-trinidad-and-tobago/retrieved

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Conduct and safeguarding for TT payment entities is governed through a set of CBTT guidelines (Market Conduct Guideline, Corporate Governance Guideline, Outsourcing Risk Guideline, Security Systems for Safeguarding Customer Information) layered onto the EMI Order's capital/safeguarding/consumer-protection conditions, with the industry-run Office of the Financial Services Ombudsman (OFSO) providing a complaints-resolution backstop and the CBTT retaining direct enforcement power (e.g., registration revocation) over non-compliant EMIs.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.elibrary.imf.org/view/journals/002/2023/322/article-A001-en.xmlretrieved
  2. T1https://www.elibrary.imf.org/view/journals/002/2023/161/article-A001-en.xmlretrieved
  3. T1https://foreign.gov.tt/documents/1391/E-Money_-_LN2023_391_240130_095235.pdfretrieved
  4. T2https://batt.org.tt/consumer-awareness/retrieved
  5. T1https://www.central-bank.org.tt/news-centre/latest-news?keys=&items_per_page=10&page=2retrieved

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TT's digital-money regime is currently e-money-only: the FIA (2008) and the E-Money Issuer Order 2020/2023 govern e-money issuance by both licensees and approved non-bank EMIs; there is no dedicated crypto-asset or stablecoin statute in force, and crypto assets remain formally unregulated/unsupervised, though a Virtual Assets and Virtual Assets Service Providers Bill (Bill No. 8 of 2025) is now before Parliament and CBDC feasibility research (with IMF technical assistance) is ongoing without a firm implementation timeline.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (6)
  1. T1https://www.elibrary.imf.org/view/journals/002/2023/322/article-A001-en.xmlretrieved
  2. T1https://www.elibrary.imf.org/view/journals/002/2023/322/article-A001-en.xmlretrieved
  3. T1https://www.ttparliament.org/publications/bills/retrieved
  4. T4https://freemanlaw.com/cryptocurrency/trinidad-and-tobago/retrieved
  5. T3https://cbdctracker.hrf.org/currency/trinidad-and-tobagoretrieved
  6. T1https://foreign.gov.tt/documents/1391/E-Money_-_LN2023_391_240130_095235.pdfretrieved

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Operational resilience for TT financial institutions rests on the CBTT's 2023 Cybersecurity Best Practices Guideline (mandatory incident reporting and annual self-assessment for regulated entities), layered on earlier outsourcing-risk and customer-information-security guidelines, with the RTGS/safe-tt system operated under PFMI standards the Bank adopted in 2014; an IMF technical-assistance mission found the pre-2023 cyber regulatory environment fragmented across several indirect guidelines.

Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. Open its jurisdiction pages on Dataprotection.gi →

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.central-bank.org.tt/core-functions/financial-stability/cybersecurity/retrieved
  2. T1https://www.central-bank.org.tt/cbtt_storage/2025/07/circular-letter-cybersecurity-best-practices-guideline-november2023-july2025.pdfretrieved
  3. T1https://www.central-bank.org.tt/fintech-and-payments/payment-system-landscape/retrieved
  4. T1https://www.imf.org/en/Publications/high-level-summary-technical-assistance-reports/Issues/2023/04/17/TRINIDAD-AND-TOBAGO-STRENGTHENING-CYBERSECURITY-IN-FINANCIAL-INSTITUTIONS-532437retrieved
  5. T2https://tatt.org.tt/wp-content/uploads/2024/10/Guidelines-for-Cybersecurity-of-Public-Telecom-Networks-15102024.pdfretrieved

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TT's domestic card/ACH rail is InfoLink Services Limited's LINX debit-switching network and ACH clearing system, a bank-owned joint venture designated by CBTT as a Significant Retail Payment System; on the international card side, PCI DSS compliance is mandatory for all merchants handling card data, enforced through acquiring-bank compliance programmes rather than a dedicated TT statute.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.central-bank.org.tt/fintech-and-payments/payment-system-landscape/retrieved
  2. T3https://newsday.co.tt/2025/11/20/money-linx-infolink-prepares-for-its-next-three-decades/retrieved
  3. T2https://infolink.co.tt/linx/retrieved
  4. T2https://www.firstcitizensgroup.com/tt/compliance-with-payment-card-industry-data-security-standards-pci-dss/retrieved
  5. T1https://www.central-bank.org.tt/core-functions/financial-stability/banking-sector/retrieved

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TT's principal corridors are the remittance channel with North America/UK (Western Union, MoneyGram, GraceKennedy Money Services), where persistent USD/forex shortages since 2015 have lengthened conversion timelines, and a newly-built domestic instant-payments corridor being developed with India's NPCI International under a UPI-modelled bilateral partnership signed September 2024, targeting P2P/P2M/G2P transfers.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://mpaai.gov.tt/news/ministry-signs-agreement-real-time-payment-platformretrieved
  2. T1https://www.trade.gov/country-commercial-guides/trinidad-and-tobago-trade-financingretrieved
  3. T3https://www.shabariseva.com/post/trinidad-and-tobago-emerges-as-pioneer-in-caribbean-digital-payments-by-adopting-india-s-upi-platforretrieved
  4. T4https://massyremittance.com/services/trinidad-and-tobago/retrieved
  5. T3https://www.csis.org/analysis/there-new-normal-de-risking-caribbeanretrieved

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TT's payments-adjacent banking sector comprises eight CBTT-licensed commercial banks (Republic Bank, First Citizens, Scotiabank TT, RBC, CIBC/FirstCaribbean, JMMB and others), with Republic Bank historically dominant; a small but growing non-bank fintech layer (WiPay, PayWise, and 11 CBTT-supervised PSPs as of 2025) is emerging alongside the banks, with WiPay expanding regionally into a 12-country group structure.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.central-bank.org.tt/core-functions/financial-stability/banking-sector/retrieved
  2. T3https://oxfordbusinessgroup.com/overview/solid-ground-lenders-enjoy-continued-profitability-although-sector-growth-has-slowedretrieved
  3. T3https://thefintechtimes.com/trinidad-and-tobago-preparing-for-payments-revolution/retrieved
  4. T4https://www.wipaygroup.com/retrieved
  5. T4https://tracxn.com/d/explore/financial-services-startups-in-trinidad-and-tobago/__F6DNzE82sD7hDOc9VeCkVDNyUrhM5VzCpYXRLFmcxVoretrieved

TT's payments-adjacent enforcement landscape in 2025-2026 centres on the legislative response to CFATF's 4th Round Mutual Evaluation findings: a Miscellaneous Provisions (FATF Compliance) Bill and Counter-Proliferation Financing Act raising criminal and administrative penalties for AML/CFT breaches, alongside direct CBTT enforcement action such as the 2024 revocation of an EMI's provisional registration and new mandatory trust-registration rules under the Finance Bill 2026.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.finance.gov.tt/wp-content/uploads/2025/09/Misc.-Provisions-FATF-Compliance-Bill-2025-Counter-Proliferation-Financing-Bill-2025-R.pdfretrieved
  2. T1https://www.central-bank.org.tt/cbtt_storage/2026/02/appendix-1-substantive-legislative-amendments-matrix-february-2026.pdfretrieved
  3. T1https://www.central-bank.org.tt/news-centre/latest-news?keys=&items_per_page=10&page=2retrieved
  4. T1https://www.ttparliament.org/publication/the-finance-bill-2026/retrieved
  5. T1https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/cfatf-4mer-trinidad-tobago.pdfretrieved

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Merchant acquiring in TT is conducted by the CBTT-licensed commercial banks acting as scheme acquirers; there is no TT-specific acquiring statute, so card-present/card-not-present risk management runs on global PCI DSS and Visa/Mastercard chargeback rules, with high-risk merchant categories (adult entertainment, online gambling) largely excluded from local PSP service and forced toward global high-risk aggregators.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.central-bank.org.tt/core-functions/financial-stability/banking-sector/retrieved
  2. T2https://www.firstcitizensgroup.com/tt/compliance-with-payment-card-industry-data-security-standards-pci-dss/retrieved
  3. T2https://www.firstcitizensgroup.com/tt/credit-cards/details-on-disputes/retrieved
  4. T4https://payatlas.com/countries/trinidad-and-tobago-ttretrieved
  5. T4https://payatlas.com/countries/trinidad-and-tobago-ttretrieved

#

TT's flagship 2026 product-innovation initiative is the UPI-modelled national instant-payments platform built with NPCI International, positioning TT as the first Caribbean UPI adopter; this sits alongside a CBTT Regulatory Innovation Hub/Sandbox, ongoing (but timeline-less) CBDC feasibility research, and private-sector product build-out from fintechs such as WiPay.

Standing sub-brief · as of 11 October 2026246 words · last cycle 2026-10-11

Product Innovation & Market Development

The draft Payment Systems and Services (PSS) Bill, whose public consultation closed on 20 June 2026, introduces a regulatory sandbox intended to give flexibility for innovation, including the possibility of testing new payment products and models under supervised conditions, according to the Central Bank's consultation materials. Alongside the legislative proposal, product-level innovation is already visible in the market: Republic Bank's Endcash e-money application appears on the Central Bank's published list of Approved E-Money Issuers, Payment Service Providers and Payment System Operators, as at 1 August 2026, having been approved under the Central Bank's existing New Product Guidelines. This is a bank-led e-money product that received regulatory approval under the current framework, ahead of and separate from whatever sandbox mechanism the draft PSS Bill may eventually introduce.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://mpaai.gov.tt/news/ministry-signs-agreement-real-time-payment-platformretrieved
  2. T1https://www.central-bank.org.tt/fintech-and-payments/retrieved
  3. T1https://www.imf.org/-/media/Files/Publications/CR/2023/English/1TTOEA2023003.ashxretrieved
  4. T4https://freemanlaw.com/cryptocurrency/trinidad-and-tobago/retrieved
  5. T4https://www.wipaygroup.com/retrieved

#

Financial consumer protection in TT runs through the Office of the Financial Services Ombudsman (OFSO), an industry/Central-Bank-established free mediation body for individual and small-business complaints against banks, complemented by the general Consumer Affairs Division; no dedicated mandatory APP-fraud reimbursement regime analogous to the UK PSR model was identified as being in force.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T2https://www.ofso.org.tt/index.php/about-us/retrieved
  2. T2https://batt.org.tt/consumer-awareness/retrieved
  3. T1https://www.bis.org/review/r130513a.pdfretrieved
  4. T4https://lawzana.com/index.php/consumer-protection-lawyers/trinidad-and-tobagoretrieved

#

Sentinel.gi position (payments-context, carried not originated): TT's AML/CFT regime is under active remediation following FATF/CFATF-identified strategic deficiencies -- FIUTT sits in FATF Procedural Trigger 3 -- with 2025/2026 legislative reforms (FATF Compliance Bill, Counter-Proliferation Financing Act, NRA2-informed FIUTT guidance) strengthening administrative fines and beneficial-ownership transparency.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (8)
  1. T1sentinel.https://www.finance.gov.tt/divisions/financial-intelligence-unit-of-trinidad-and-tobago/
  2. T?FIM (sentinel.gi) per-JID baseline profile — Trinidad and Tobago — AML/CFT regime rests on the Proceeds of Crime Act (POCA, Chap 11:27), Anti-Terrorism Act, FIU Act 2009, Financial Obligations Regulations 2010, Economic Sanctions Act, and new Counter-Proliferation Financing Act 2025. FIUTT is national AML/CFT Supervisory Authority for non-regulated FIs/listed businesses; TTSEC and CBTT supervise securities and banking. CFATF member undergoing 5th Round Mutual Evaluation (onsite ~Mar 2026).
  3. T1FIM (sentinel.gi) regulatory_horizon_register (issue FIM-BASE-HRZ-003) — VA/VASP Act 2025 prohibition period sunset
  4. T1FIM (sentinel.gi) regulatory_horizon_register (issue FIM-BASE-HRZ-002) — CFATF Plenary discussion of Trinidad and Tobago 5th Round MER
  5. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: enforcement-absence
  6. T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: OFSI divergence
  7. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap
  8. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: regulatory-failure

#

TT's domestic large-value settlement runs through the CBTT-owned RTGS (safe-tt) system among eight direct-participant banks, while cross-border correspondent banking access has been under structural pressure from de-risking -- TT is one of 12 Caribbean jurisdictions to have lost correspondent relationships -- partially offset by Republic Financial Holdings' emergence as a regional correspondent alternative and sustained CARICOM/US diplomatic engagement on the issue.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.central-bank.org.tt/fintech-and-payments/payment-system-landscape/retrieved
  2. T3https://bahamasamlconference.centralbankbahamas.com/documents/2024-03-26-16-43-54-De-Risking-in-the-Caribbean-a-CFATF-Perspective-Pragg-Jaggernauth.pdfretrieved
  3. T3https://www.csis.org/analysis/there-new-normal-de-risking-caribbeanretrieved
  4. T4https://sylviagarcia.house.gov/media/in-the-news/pm-rowley-calls-greater-cooperation-between-caribbean-and-us-banksretrieved
  5. T3https://cert-net.com/files/publications/working_papers/2016TWGDR.pdfretrieved

#

Trailing-12-month commercial activity in TT payments is dominated by CBTT regulatory-registration events (new/expanded PSP and EMI registrations) and the NPCI/UPI national-rail build-out, rather than disclosed M&A or funding rounds; no material acquisition or disclosed funding round involving a TT payments entity was identified within the window.

Standing sub-brief · as of 11 October 2026232 words · last cycle 2026-10-11

Commercial Intelligence & Fintech

The Central Bank of Trinidad and Tobago granted Convenience Pay Technologies Limited, a subsidiary of UNIPET, provisional registration as a Payment Service Provider authorised to issue electronic money, effective 3 June 2026, for a six-month period in a controlled environment. The transaction value or investment amount associated with this registration was not publicly disclosed. The registration predates the current periodic research window and is captured here as a confirmed backfill item rather than a within-window development; the Central Bank's own sector-licensing review of the application was recorded as cleared.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://www.central-bank.org.tt/central-bank-registers-gracekennedy-trinidad-tobago-limited-as-a-payment-service-provider-in-trinidad-and-tobago/retrieved
  2. T1https://www.central-bank.org.tt/central-bank-authorizes-convenience-pay-technologies-limited-as-a-payment-service-provider-registered-to-issue-electronic-money-in-trinidad-and-tobago/retrieved
  3. T3https://newsday.co.tt/2025/11/20/money-linx-infolink-prepares-for-its-next-three-decades/retrieved
  4. T1https://www.central-bank.org.tt/last-call-for-submissions-the-public-consultation-on-the-draft-payment-systems-and-services-bill-pss-and-accompanying-regulations/retrieved
  5. T1https://www.ttparliament.org/publications/bills/retrieved
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