--- title: "TT Payments Regulation Monitor | World Payments Monitor" canonical: https://payments.gi/jurisdictions/trinidad-and-tobago/ source_html: /jurisdictions/trinidad-and-tobago/index.html description: "TT payments and e-money regulation: 14 modules, 76 sourced findings, updated 2026-10-26. Licensing, safeguarding, stablecoins, AML/CFT." generated_at: 2026-10-26T19:20:26Z content_sha256: 4ac7b51b2f6f7bb7d00518cddca2815332fafb21e4ad6cd4f61c9b59c96647ce generator: "fe-fleet/md-twin@1.0" --- # TT TT schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-26 · 14 modules · 76 sourced findings · 134 sources in the cumulative register Download report (PDF) Expand all 14 Modules 0 Moved this cycle 1 Key judgments 3 Open gaps 76 Findings 47 Tier-1 sources Confidence mix 4 confirmed 10 unpopulated (sums to 14 rendered modules; click to filter) No modules moved this cycle. ## Jurisdiction brief Jurisdiction lead brief 874 Full executive summary 503 ###### Latest update · 25 October 2026 #### Lead Signal The Central Bank of Trinidad and Tobago has published Licensing Procedures for Payment System Operators, Version 1.0, in October 2026, ahead of the still-draft Payment Systems and Services Bill. The procedures draw on the Central Bank Act, the Financial Institutions Act, the Bank's existing Payments System Guidelines No.1 and No.2, and the draft Bill and draft regulations themselves, and they are stated to align with the CPMI-IOSCO Principles for Financial Market Infrastructures Assessment Methodology, particularly Responsibilities A through E for systems. The practical reading is that the Bank is operationalising payment system operator licensing under its existing statutory powers rather than waiting for the Payment Systems and Services Bill to pass into law. The Bill itself remains described as a draft instrument in the October 2026 procedures, and whether it was laid before Parliament by a previously stated September 2026 target has not been independently confirmed. #### Other Developments A notable downstream dependency has surfaced from outside the payments sector proper: Trinidad and Tobago's parliament has approved legislation permitting remote gambling operators to offer services internationally, and officials have indicated that the Gambling Control Commission is coordinating with the Central Bank on digital-payment integration and licensing for electronic-money issuers as part of bringing that market to launch, targeted for around January 2027. This ties the timetable for a new licensed market's opening to the pace of the Central Bank's own payment-licensing work, which is itself proceeding ahead of the formal Payment Systems and Services Bill through the administrative procedures described above. #### Cross-Monitor Connections The coordination between the Gambling Control Commission and the Central Bank on digital-payment integration and electronic-money-issuer licensing connects this jurisdiction's payment-licensing track directly to its gambling-sector liberalisation: the remote gambling licence created by the recently approved Order is understood to be conditioned in practice on that payment and e-money infrastructure being in place, so a delay on the Central Bank's licensing side would delay the gambling market's opening in turn, independent of anything the gambling regulator does on its own. #### Outlook Watch for confirmation of whether the Payment Systems and Services Bill has been laid before Parliament, and for the Central Bank's progress on electronic-money-issuer licensing, since that progress now has a second, visible client in the gambling sector's own launch timetable. A published list of Central Bank-approved electronic-money issuers, payment service providers, or payment system operators dated within the current window would materially sharpen the market-access picture; none has been located as yet. 1 earlier update not shown here. ###### Standing brief · as of 4 October 2026 Written before the update above. Where they differ, the update is the more recent position. #### Lead Signal Trinidad and Tobago's payment-licensing landscape moved this cycle on the back of the Remote Gambling Order, 2026's passage through Parliament. 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 the first direct statement tying the Central Bank's e-money licensing track and its draft Payment Systems and Services Bill to a specific sectoral launch date, elevating the practical stakes of finalising both workstreams on schedule. #### Other Developments CBTT's existing e-money issuer register. The Central Bank's own published list of licensed e-money issuers and payment service providers, current as at 1 August 2026, shows PayWise, PESH Money, TSTT-PAYPR, Massy's WIDiT, WamNow Technologies and Convenience Pay Technologies registered, alongside Republic Bank's Endcash wallet, approved under the Central Bank's New Product Guidelines. Any entity licensed under the Financial Institutions Act Chap 79:09 may issue e-money subject to Central Bank approval, meaning the regulatory gateway for new e-money issuance already exists independently of the gambling-sector development; what is new is the explicit link between that gateway and the gambling rollout timeline. Draft Payment Systems and Services Bill remains at consultation. The comprehensive Payment Systems and Services Bill and accompanying regulations, which would create a systemic-designation power and strengthen safeguarding and consumer-protection rules for payment providers, remained at consultation stage as at the most recent circular located this cycle. No enactment has been identified. The Bill's consultation status is a carried-forward standing position, now read against the newly confirmed link to the remote-gambling payments timeline. #### Cross-Monitor Connections The payment-systems reform track intersects directly with the gambling-sector regulatory timeline: the same ministerial statement that confirmed Central Bank coordination on e-money licensing also ties that work to the targeted January 2027 remote-gambling rollout, meaning the pace of the PSS Bill's progress is now a dependency for the gambling sector's own market-access timeline, not solely a domestic payments-reform matter. #### Outlook The practical question for market access in Trinidad and Tobago's payments sector is whether the draft Payment Systems and Services Bill moves from consultation to enactment on a timeline consistent with the gambling sector's targeted January 2027 launch. Given the Minister's statement linking the two tracks, the Bill's systemic-designation power and strengthened safeguarding rules would, if enacted, apply directly to whatever payment rails are built to serve the remote-gambling sector, making its legislative progress a signal worth tracking independently of the gambling-sector news itself. Read full brief · 874 words ###### Latest update · 25 October 2026 #### Regulatory Status The Central Bank of Trinidad and Tobago published Licensing Procedures for Payment System Operators, Version 1.0, in October 2026, drawing on the Central Bank Act, the Financial Institutions Act, its existing Payments System Guidelines No.1 and No.2, and the still-draft Payment Systems and Services Bill and draft regulations. The procedures are stated to align with the CPMI-IOSCO Principles for Financial Market Infrastructures Assessment Methodology, particularly Responsibilities A through E of systems. The Payment Systems and Services Bill itself remains a draft instrument, and confirmation that it was laid before Parliament by a previously stated September 2026 target has not been independently obtained. Separately, Trinidad and Tobago's parliament has approved an Order permitting remote gambling operators to offer services internationally, and the targeted launch of that market, expected around January 2027, has been linked administratively to coordination between the Gambling Control Commission and the Central Bank on digital-payment integration and electronic-money-issuer licensing. This creates a direct dependency between the pace of the Central Bank's payment-licensing work and the opening of the newly liberalised gambling market. #### Outlook The markers to watch are confirmation of the Payment Systems and Services Bill's parliamentary status, progress on Central Bank electronic-money-issuer licensing, and publication of a current list of Central Bank-approved payment system operators, payment service providers, or electronic-money issuers, none of which has yet been located in the available record. ###### Standing brief · as of 11 October 2026 Written before the update above. Where they differ, the update is the more recent position. #### Regulatory Status Trinidad and Tobago's payments regulatory environment is in active transition. The Central Bank's public consultation on the draft Payment Systems and Services (PSS) Bill and accompanying regulations closed on 20 June 2026, proposing a regulatory sandbox, simplified licensing, enhanced interoperability requirements, and an alternative dispute resolution mechanism for payment complaints; the bill has not yet been enacted. Within the existing framework, the Central Bank granted Convenience Pay Technologies Limited, a UNIPET subsidiary, provisional registration as a Payment Service Provider authorised to issue electronic money, effective 3 June 2026, for a six-month controlled-environment period. Separately, 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, approved under the Central Bank's New Product Guidelines. In a related but distinct development, 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. #### Outlook The principal item to watch is whether and when the draft PSS Bill is enacted following the close of its consultation on 20 June 2026, introducing the proposed sandbox and simplified-licensing provisions. The six-month controlled-environment period attached to Convenience Pay Technologies Limited's registration, dated from 3 June 2026, is a further near-term date, as is the trajectory of the gambling-sector payment oversight architecture referenced by government ministers, which has not yet been confirmed as operational. Read full brief · 503 words × 14 of 14 modules Signal Moved Judgment Gap Density Comfortable Compact Expand all sources Reset all Selections OR within a group, AND across groups. Press / to search. ### W1aLicensing, Authorisation & Market Access1 judgment2 gapConfirmedconfirmed 2026-09-08▾# 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. Key judgment — Probable · impact ELEVATED CBTT has moved ahead of the still-draft PSS Bill by issuing administrative licensing procedures, suggesting the Bank intends to operationalise PSO licensing under existing powers (CBA, FIA, Guidelines) rather than wait for the Bill's passage. claims: wpm-2026-W43-001, wpm-2026-W43-002 Open gap — wpm-int-1 Could not confirm whether the Payment Systems and Services Bill was laid in Parliament by the stated September 2026 target. no under-indexing note recorded Open gap — wpm-int-3 Did not locate a current list of CBTT-approved e-money issuers/PSPs/PSOs dated within this cycle's window. no under-indexing note recorded Horizon · 2026-Q4 (± six months) TT Payment Systems and Services Bill consultation ongoing Consultation · Tier 3 source Horizon · 2027-Q1 (± a year) Draft PSS Bill expected enactment Consultation · Tier 1 source Standing sub-brief · as of 4 October 2026 409 words · last cycle 2026-10-25 #### 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. The existing licensing gateway itself is well established and unchanged in its basic structure: any entity licensed under the Financial Institutions Act Chap 79:09 may issue e-money subject to Central Bank approval. The Central Bank's own published register of e-money issuers and payment service providers, current as at 1 August 2026, lists PayWise, PESH Money, TSTT-PAYPR, Massy's WIDiT, WamNow Technologies and Convenience Pay Technologies, alongside Republic Bank's Endcash wallet, which was approved separately under the Central Bank's New Product Guidelines rather than through the standard e-money licensing route. This confirms that Trinidad and Tobago already has a functioning, if modest, population of licensed non-bank and bank-affiliated e-money issuers prior to any gambling-sector development. What remains unresolved is the comprehensive Payment Systems and Services Bill and its accompanying regulations, which would create a systemic-designation power and strengthen safeguarding and consumer-protection rules for payment providers generally. As at the most recent circular located this cycle, the Bill remained at consultation stage, with no enactment identified. The Bill's progress is now, per the Minister's statement, linked to the gambling-sector rollout timeline, which raises the practical stakes of its finalisation beyond the payments sector's own internal reform calendar. #### Outlook The central question to track is whether the draft Payment Systems and Services Bill moves from consultation to enactment on a schedule consistent with the gambling sector's targeted January 2027 launch date. Given the explicit ministerial linkage between the two tracks, delay in the Bill's progress would now carry consequences for the gambling sector's own market-access timeline, not only for the payments sector's reform agenda. Separately, watch whether any of the entities on the Central Bank's existing e-money issuer and payment service provider register, or a new entrant, emerges as the designated payment rail for the remote-gambling sector once licensing opens on the gambling side. Read full sub-brief · 409 words Periodic update · new data 2026-10-25 #### Licensing, Authorisation & Market Access The Central Bank of Trinidad and Tobago published Licensing Procedures for Payment System Operators, Version 1.0 (document code PFMID-PROC-PSOLIS-092026), in October 2026. The procedures draw on the Central Bank Act, the Financial Institutions Act, the Bank's Payments System Guidelines No.1 and No.2, and the still-draft Payment Systems and Services Bill and its accompanying draft regulations. The Bank has stated the procedures align with the CPMI-IOSCO Principles for Financial Market Infrastructures Assessment Methodology, with particular reference to Responsibilities A through E of systems, which concern legal basis, governance, risk management frameworks for credit and liquidity risk, settlement finality, and money settlement arrangements for financial market infrastructures. The significance of the timing is that the Payment Systems and Services Bill itself remains a draft instrument, and whether it has been laid before Parliament by a previously stated September 2026 target has not been independently confirmed. The Bank appears to be moving ahead of the Bill's passage by issuing administrative licensing procedures under powers it already holds, rather than waiting for the new legislative framework to be enacted before beginning to license payment system operators. This procedure applies across both bank and non-bank applicants. A second development gives the licensing track added weight beyond the payments sector itself: Trinidad and Tobago's parliament has approved an Order permitting remote gambling operators to offer services internationally, and the targeted launch of that market has been linked administratively to the Gambling Control Commission's coordination with the Central Bank on digital-payment integration and electronic-money-issuer licensing. That means the pace of the Central Bank's own licensing procedures, including the newly published Version 1.0 procedures, now has a direct bearing on when a separate, newly liberalised market can open. #### Outlook Confirmation of whether the Payment Systems and Services Bill has been laid before Parliament remains an open point, as does the publication of a current list of Central Bank-approved electronic-money issuers, payment service providers, or payment system operators. Given the newly identified dependency from the gambling sector's remote-gambling launch, targeted for around January 2027, progress on electronic-money-issuer licensing at the Central Bank is now a marker worth tracking for two separate regulatory stories rather than one. 1 earlier distinct update(s) 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. Evidence 8 Sources and findings (8) - T1[https://www.central-bank.org.tt/registration-payment-service-providers-bill-payment-service-providers-and/](https://www.central-bank.org.tt/registration-payment-service-providers-bill-payment-service-providers-and/)retrieved 2026-09-08 - T1[https://www.central-bank.org.tt/fintech-and-payments/payment-services/](https://www.central-bank.org.tt/fintech-and-payments/payment-services/)retrieved 2026-09-08 - T1[https://www.central-bank.org.tt/fintech-and-payments/payment-system-landscape/](https://www.central-bank.org.tt/fintech-and-payments/payment-system-landscape/)retrieved 2026-09-08 - T1[https://foreign.gov.tt/documents/1391/E-Money_-_LN2023_391_240130_095235.pdf](https://foreign.gov.tt/documents/1391/E-Money_-_LN2023_391_240130_095235.pdf)retrieved 2026-09-08 - T1[https://www.elibrary.imf.org/view/journals/002/2023/322/article-A001-en.xml](https://www.elibrary.imf.org/view/journals/002/2023/322/article-A001-en.xml) Applies beyond this jurisdiction (IMF)retrieved 2026-09-08 - T1[https://www.central-bank.org.tt/fintech-and-payments/payment-services/](https://www.central-bank.org.tt/fintech-and-payments/payment-services/)retrieved 2026-09-08 - T3[https://www.ttt.live/public-consultations-continue-on-draft-payment-systems-and-services-bill/](https://www.ttt.live/public-consultations-continue-on-draft-payment-systems-and-services-bill/)retrieved 2026-09-08 - T1[https://www.central-bank.org.tt/central-bank-registers-gracekennedy-trinidad-tobago-limited-as-a-payment-service-provider-in-trinidad-and-tobago/](https://www.central-bank.org.tt/central-bank-registers-gracekennedy-trinidad-tobago-limited-as-a-payment-service-provider-in-trinidad-and-tobago/)retrieved 2026-09-08 ### W1bConduct, Safeguarding & PromotionsProbableconfirmed 2026-09-08▾# 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 determinable No 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 Evidence 5 Sources and findings (5) - T1[https://www.elibrary.imf.org/view/journals/002/2023/322/article-A001-en.xml](https://www.elibrary.imf.org/view/journals/002/2023/322/article-A001-en.xml) Applies beyond this jurisdiction (IMF)retrieved 2026-09-08 - T1[https://www.elibrary.imf.org/view/journals/002/2023/161/article-A001-en.xml](https://www.elibrary.imf.org/view/journals/002/2023/161/article-A001-en.xml) Applies beyond this jurisdiction (IMF)retrieved 2026-09-08 - T1[https://foreign.gov.tt/documents/1391/E-Money_-_LN2023_391_240130_095235.pdf](https://foreign.gov.tt/documents/1391/E-Money_-_LN2023_391_240130_095235.pdf)retrieved 2026-09-08 - T2[https://batt.org.tt/consumer-awareness/](https://batt.org.tt/consumer-awareness/)retrieved 2026-09-08 - T1[https://www.central-bank.org.tt/news-centre/latest-news?keys=&items_per_page=10&page=2](https://www.central-bank.org.tt/news-centre/latest-news?keys=&items_per_page=10&page=2)retrieved 2026-09-08 ### W2Stablecoins & Digital MoneyProbableconfirmed 2026-09-08▾# 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 determinable No 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 Evidence 6 Sources and findings (6) - T1[https://www.elibrary.imf.org/view/journals/002/2023/322/article-A001-en.xml](https://www.elibrary.imf.org/view/journals/002/2023/322/article-A001-en.xml) Applies beyond this jurisdiction (IMF)retrieved 2026-09-08 - T1[https://www.elibrary.imf.org/view/journals/002/2023/322/article-A001-en.xml](https://www.elibrary.imf.org/view/journals/002/2023/322/article-A001-en.xml) Applies beyond this jurisdiction (IMF)retrieved 2026-09-08 - T1[https://www.ttparliament.org/publications/bills/](https://www.ttparliament.org/publications/bills/)retrieved 2026-09-08 - T4[https://freemanlaw.com/cryptocurrency/trinidad-and-tobago/](https://freemanlaw.com/cryptocurrency/trinidad-and-tobago/)retrieved 2026-09-08 - T3[https://cbdctracker.hrf.org/currency/trinidad-and-tobago](https://cbdctracker.hrf.org/currency/trinidad-and-tobago)retrieved 2026-09-08 - T1[https://foreign.gov.tt/documents/1391/E-Money_-_LN2023_391_240130_095235.pdf](https://foreign.gov.tt/documents/1391/E-Money_-_LN2023_391_240130_095235.pdf)retrieved 2026-09-08 ### W3Operational Resilience & Critical InfraConfirmedconfirmed 2026-09-08▾# 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 →](https://dataprotection.gi/jurisdictions/) Absence reason not determinable No 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 Evidence 5 Sources and findings (5) - T1[https://www.central-bank.org.tt/core-functions/financial-stability/cybersecurity/](https://www.central-bank.org.tt/core-functions/financial-stability/cybersecurity/)retrieved 2026-09-08 - T1[https://www.central-bank.org.tt/cbtt_storage/2025/07/circular-letter-cybersecurity-best-practices-guideline-november2023-july2025.pdf](https://www.central-bank.org.tt/cbtt_storage/2025/07/circular-letter-cybersecurity-best-practices-guideline-november2023-july2025.pdf)retrieved 2026-09-08 - T1[https://www.central-bank.org.tt/fintech-and-payments/payment-system-landscape/](https://www.central-bank.org.tt/fintech-and-payments/payment-system-landscape/)retrieved 2026-09-08 - T1[https://www.imf.org/en/Publications/high-level-summary-technical-assistance-reports/Issues/2023/04/17/TRINIDAD-AND-TOBAGO-STRENGTHENING-CYBERSECURITY-IN-FINANCIAL-INSTITUTIONS-532437](https://www.imf.org/en/Publications/high-level-summary-technical-assistance-reports/Issues/2023/04/17/TRINIDAD-AND-TOBAGO-STRENGTHENING-CYBERSECURITY-IN-FINANCIAL-INSTITUTIONS-532437) Applies beyond this jurisdiction (IMF)retrieved 2026-09-08 - T2[https://tatt.org.tt/wp-content/uploads/2024/10/Guidelines-for-Cybersecurity-of-Public-Telecom-Networks-15102024.pdf](https://tatt.org.tt/wp-content/uploads/2024/10/Guidelines-for-Cybersecurity-of-Public-Telecom-Networks-15102024.pdf)retrieved 2026-09-08 ### W4Scheme & Network ComplianceProbableconfirmed 2026-09-08▾# 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 determinable No 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 Evidence 5 Sources and findings (5) - T1[https://www.central-bank.org.tt/fintech-and-payments/payment-system-landscape/](https://www.central-bank.org.tt/fintech-and-payments/payment-system-landscape/)retrieved 2026-09-08 - T3[https://newsday.co.tt/2025/11/20/money-linx-infolink-prepares-for-its-next-three-decades/](https://newsday.co.tt/2025/11/20/money-linx-infolink-prepares-for-its-next-three-decades/)retrieved 2026-09-08 - T2[https://infolink.co.tt/linx/](https://infolink.co.tt/linx/)retrieved 2026-09-08 - T2[https://www.firstcitizensgroup.com/tt/compliance-with-payment-card-industry-data-security-standards-pci-dss/](https://www.firstcitizensgroup.com/tt/compliance-with-payment-card-industry-data-security-standards-pci-dss/)retrieved 2026-09-08 - T1[https://www.central-bank.org.tt/core-functions/financial-stability/banking-sector/](https://www.central-bank.org.tt/core-functions/financial-stability/banking-sector/)retrieved 2026-09-08 ### W5Payment Corridor DynamicsProbableconfirmed 2026-09-08▾# 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 determinable No 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 Evidence 5 Sources and findings (5) - T1[https://mpaai.gov.tt/news/ministry-signs-agreement-real-time-payment-platform](https://mpaai.gov.tt/news/ministry-signs-agreement-real-time-payment-platform)retrieved 2026-09-08 - T1[https://www.trade.gov/country-commercial-guides/trinidad-and-tobago-trade-financing](https://www.trade.gov/country-commercial-guides/trinidad-and-tobago-trade-financing)retrieved 2026-09-08 - T3[https://www.shabariseva.com/post/trinidad-and-tobago-emerges-as-pioneer-in-caribbean-digital-payments-by-adopting-india-s-upi-platfor](https://www.shabariseva.com/post/trinidad-and-tobago-emerges-as-pioneer-in-caribbean-digital-payments-by-adopting-india-s-upi-platfor)retrieved 2026-09-08 - T4[https://massyremittance.com/services/trinidad-and-tobago/](https://massyremittance.com/services/trinidad-and-tobago/)retrieved 2026-09-08 - T3[https://www.csis.org/analysis/there-new-normal-de-risking-caribbean](https://www.csis.org/analysis/there-new-normal-de-risking-caribbean)retrieved 2026-09-08 ### W6Industry Structure & CommercialProbableconfirmed 2026-09-08▾# 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 determinable No 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 Evidence 5 Sources and findings (5) - T1[https://www.central-bank.org.tt/core-functions/financial-stability/banking-sector/](https://www.central-bank.org.tt/core-functions/financial-stability/banking-sector/)retrieved 2026-09-08 - T3[https://oxfordbusinessgroup.com/overview/solid-ground-lenders-enjoy-continued-profitability-although-sector-growth-has-slowed](https://oxfordbusinessgroup.com/overview/solid-ground-lenders-enjoy-continued-profitability-although-sector-growth-has-slowed)retrieved 2026-09-08 - T3[https://thefintechtimes.com/trinidad-and-tobago-preparing-for-payments-revolution/](https://thefintechtimes.com/trinidad-and-tobago-preparing-for-payments-revolution/)retrieved 2026-09-08 - T4[https://www.wipaygroup.com/](https://www.wipaygroup.com/)retrieved 2026-09-08 - T4[https://tracxn.com/d/explore/financial-services-startups-in-trinidad-and-tobago/__F6DNzE82sD7hDOc9VeCkVDNyUrhM5VzCpYXRLFmcxVo](https://tracxn.com/d/explore/financial-services-startups-in-trinidad-and-tobago/__F6DNzE82sD7hDOc9VeCkVDNyUrhM5VzCpYXRLFmcxVo)retrieved 2026-09-08 ### W7Legal & LitigationConfirmedconfirmed 2026-09-08▾# 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 determinable No 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 Evidence 5 Sources and findings (5) - T1[https://www.finance.gov.tt/wp-content/uploads/2025/09/Misc.-Provisions-FATF-Compliance-Bill-2025-Counter-Proliferation-Financing-Bill-2025-R.pdf](https://www.finance.gov.tt/wp-content/uploads/2025/09/Misc.-Provisions-FATF-Compliance-Bill-2025-Counter-Proliferation-Financing-Bill-2025-R.pdf)retrieved 2026-09-08 - T1[https://www.central-bank.org.tt/cbtt_storage/2026/02/appendix-1-substantive-legislative-amendments-matrix-february-2026.pdf](https://www.central-bank.org.tt/cbtt_storage/2026/02/appendix-1-substantive-legislative-amendments-matrix-february-2026.pdf)retrieved 2026-09-08 - T1[https://www.central-bank.org.tt/news-centre/latest-news?keys=&items_per_page=10&page=2](https://www.central-bank.org.tt/news-centre/latest-news?keys=&items_per_page=10&page=2)retrieved 2026-09-08 - T1[https://www.ttparliament.org/publication/the-finance-bill-2026/](https://www.ttparliament.org/publication/the-finance-bill-2026/)retrieved 2026-09-08 - T1[https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/cfatf-4mer-trinidad-tobago.pdf](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/cfatf-4mer-trinidad-tobago.pdf) Applies beyond this jurisdiction (FATF)retrieved 2026-09-08 ### W8Merchant Acquiring & RiskProbableconfirmed 2026-09-08▾# 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 determinable No 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 Evidence 5 Sources and findings (5) - T1[https://www.central-bank.org.tt/core-functions/financial-stability/banking-sector/](https://www.central-bank.org.tt/core-functions/financial-stability/banking-sector/)retrieved 2026-09-08 - T2[https://www.firstcitizensgroup.com/tt/compliance-with-payment-card-industry-data-security-standards-pci-dss/](https://www.firstcitizensgroup.com/tt/compliance-with-payment-card-industry-data-security-standards-pci-dss/)retrieved 2026-09-08 - T2[https://www.firstcitizensgroup.com/tt/credit-cards/details-on-disputes/](https://www.firstcitizensgroup.com/tt/credit-cards/details-on-disputes/)retrieved 2026-09-08 - T4[https://payatlas.com/countries/trinidad-and-tobago-tt](https://payatlas.com/countries/trinidad-and-tobago-tt)retrieved 2026-09-08 - T4[https://payatlas.com/countries/trinidad-and-tobago-tt](https://payatlas.com/countries/trinidad-and-tobago-tt)retrieved 2026-09-08 ### W9Product Innovation & Market DevelopmentProbableconfirmed 2026-09-08▾# 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 2026 246 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. The combination of an already-functioning New Product Guidelines approval route, evidenced by the Endcash approval, and a prospective sandbox mechanism under the draft PSS Bill, suggests Trinidad and Tobago's product-innovation pathway is incremental rather than a single-step change: new products can already reach market under the existing guidelines, and the draft bill would add a further, more flexible route alongside it. #### Outlook The draft PSS Bill's sandbox provision, once enacted, would be the next step-change in Trinidad and Tobago's product-innovation pathway; no enactment date has been confirmed. In the interim, the existing New Product Guidelines route, evidenced by the Endcash approval as at 1 August 2026, remains the operative channel for new payment product approval. Read full sub-brief · 246 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://mpaai.gov.tt/news/ministry-signs-agreement-real-time-payment-platform](https://mpaai.gov.tt/news/ministry-signs-agreement-real-time-payment-platform)retrieved 2026-09-08 - T1[https://www.central-bank.org.tt/fintech-and-payments/](https://www.central-bank.org.tt/fintech-and-payments/)retrieved 2026-09-08 - T1[https://www.imf.org/-/media/Files/Publications/CR/2023/English/1TTOEA2023003.ashx](https://www.imf.org/-/media/Files/Publications/CR/2023/English/1TTOEA2023003.ashx) Applies beyond this jurisdiction (IMF)retrieved 2026-09-08 - T4[https://freemanlaw.com/cryptocurrency/trinidad-and-tobago/](https://freemanlaw.com/cryptocurrency/trinidad-and-tobago/)retrieved 2026-09-08 - T4[https://www.wipaygroup.com/](https://www.wipaygroup.com/)retrieved 2026-09-08 ### W10Consumer Protection & APP FraudProbableconfirmed 2026-09-08▾# 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 determinable No 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 Evidence 4 Sources and findings (4) - T2[https://www.ofso.org.tt/index.php/about-us/](https://www.ofso.org.tt/index.php/about-us/)retrieved 2026-09-08 - T2[https://batt.org.tt/consumer-awareness/](https://batt.org.tt/consumer-awareness/)retrieved 2026-09-08 - T1[https://www.bis.org/review/r130513a.pdf](https://www.bis.org/review/r130513a.pdf) Applies beyond this jurisdiction (Basel Committee)retrieved 2026-09-08 - T4[https://lawzana.com/index.php/consumer-protection-lawyers/trinidad-and-tobago](https://lawzana.com/index.php/consumer-protection-lawyers/trinidad-and-tobago)retrieved 2026-09-08 ### W11AML/CFT & Financial CrimeSourced from Sentinel.gi ↗Confirmedconfirmed 2026-09-08▾# 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 determinable No 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 Evidence 8 Sources and findings (8) - T1sentinel.https://www.finance.gov.tt/divisions/financial-intelligence-unit-of-trinidad-and-tobago/ - 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). - T1FIM (sentinel.gi) regulatory_horizon_register (issue FIM-BASE-HRZ-003) — VA/VASP Act 2025 prohibition period sunset - T1FIM (sentinel.gi) regulatory_horizon_register (issue FIM-BASE-HRZ-002) — CFATF Plenary discussion of Trinidad and Tobago 5th Round MER - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: enforcement-absence - T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: OFSI divergence - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: regulatory-failure ### W12Correspondent Banking, Settlement & AccessProbableconfirmed 2026-09-08▾# 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 determinable No 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 Evidence 5 Sources and findings (5) - T1[https://www.central-bank.org.tt/fintech-and-payments/payment-system-landscape/](https://www.central-bank.org.tt/fintech-and-payments/payment-system-landscape/)retrieved 2026-09-08 - T3[https://bahamasamlconference.centralbankbahamas.com/documents/2024-03-26-16-43-54-De-Risking-in-the-Caribbean-a-CFATF-Perspective-Pragg-Jaggernauth.pdf](https://bahamasamlconference.centralbankbahamas.com/documents/2024-03-26-16-43-54-De-Risking-in-the-Caribbean-a-CFATF-Perspective-Pragg-Jaggernauth.pdf)retrieved 2026-09-08 - T3[https://www.csis.org/analysis/there-new-normal-de-risking-caribbean](https://www.csis.org/analysis/there-new-normal-de-risking-caribbean)retrieved 2026-09-08 - T4[https://sylviagarcia.house.gov/media/in-the-news/pm-rowley-calls-greater-cooperation-between-caribbean-and-us-banks](https://sylviagarcia.house.gov/media/in-the-news/pm-rowley-calls-greater-cooperation-between-caribbean-and-us-banks)retrieved 2026-09-08 - T3[https://cert-net.com/files/publications/working_papers/2016TWGDR.pdf](https://cert-net.com/files/publications/working_papers/2016TWGDR.pdf)retrieved 2026-09-08 ### W13Commercial Intelligence (M&A, Investment & Product)1 gapProbableconfirmed 2026-09-08▾# 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. Open gap — wpm-int-2 Did not locate W13 M&A/investment/product events for TT payments/fintech firms dated since 2026-10-11. no under-indexing note recorded Standing sub-brief · as of 11 October 2026 232 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. This is a licensing-type commercial event rather than an M&A transaction or funding round: UNIPET, through its subsidiary Convenience Pay Technologies Limited, has obtained regulatory authorisation to operate as a non-bank e-money issuer, distinguishing it from the bank-led product approval route evidenced separately by Republic Bank's Endcash application. The controlled-environment, six-month nature of the registration indicates the Central Bank is treating the entry as a supervised pilot rather than an unconditional market authorisation. #### Outlook The six-month controlled-environment period attached to Convenience Pay Technologies Limited's registration, dated from 3 June 2026, is the near-term date to watch: conversion to a full, unconditional authorisation, an extension of the pilot, or a lapse would each signal a different assessment outcome from the Central Bank. No further commercial events involving Convenience Pay Technologies Limited or other non-bank payment institutions were identified this cycle. Read full sub-brief · 232 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://www.central-bank.org.tt/central-bank-registers-gracekennedy-trinidad-tobago-limited-as-a-payment-service-provider-in-trinidad-and-tobago/](https://www.central-bank.org.tt/central-bank-registers-gracekennedy-trinidad-tobago-limited-as-a-payment-service-provider-in-trinidad-and-tobago/)retrieved 2026-09-08 - T1[https://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/](https://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 2026-09-08 - T3[https://newsday.co.tt/2025/11/20/money-linx-infolink-prepares-for-its-next-three-decades/](https://newsday.co.tt/2025/11/20/money-linx-infolink-prepares-for-its-next-three-decades/)retrieved 2026-09-08 - T1[https://www.central-bank.org.tt/last-call-for-submissions-the-public-consultation-on-the-draft-payment-systems-and-services-bill-pss-and-accompanying-regulations/](https://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 2026-09-08 - T1[https://www.ttparliament.org/publications/bills/](https://www.ttparliament.org/publications/bills/)retrieved 2026-09-08 No modules match. 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