On February 17, 2026, the EU Economic and Financial Affairs Council officially removed Trinidad and Tobago from its list of non-cooperative tax jurisdictions. The country had been on the list since December 5, 2017 - the very first edition of the EU blacklist. Eight years, two governments, and a series of reforms later, Trinidad and Tobago joined the ranks of jurisdictions the EU considers compliant with international tax standards.
Finance Minister Tancoo had projected in the 2026 budget that removal would come by February. He was right. This is one of the clearer wins of the current administration's first year, and it deserves to be acknowledged as such.
But removal from a blacklist is not the same as recovery from one. Eight years is not a footnote. It is a period during which the country absorbed real, measurable economic damage - damage that will take considerably longer to repair than it took to inflict.
How Trinidad and Tobago Got on the List
The EU adopted its first list of non-cooperative tax jurisdictions on December 5, 2017, identifying 17 countries that had not made sufficient commitments in response to EU concerns about tax transparency, fair taxation, and compliance with international standards designed to prevent base erosion and profit shifting. Trinidad and Tobago was among them.
The core issues were structural. The country's Free Trade Zone regime, established under the Free Zones Act, provided tax incentives that the EU's Code of Conduct Group considered harmful - they facilitated profit shifting without requiring genuine economic activity. Trinidad and Tobago had not signed the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters, limiting its ability to exchange tax information with other jurisdictions. And the country's transparency framework had been found wanting: in 2011, the Global Forum on Transparency and Exchange of Information rated Trinidad and Tobago "non-compliant" with several key international standards.
These were not obscure technical deficiencies. They were well-understood gaps that the EU, the OECD, and the Global Forum had flagged repeatedly. The reforms required to address them were known. Yet year after year, through successive reviews from 2018 through 2025, Trinidad and Tobago remained on Annex I - the blacklist proper - alongside jurisdictions like American Samoa, Guam, and Vanuatu.
What It Took to Get Off
The reforms that ultimately secured the delisting came in a concentrated burst between 2022 and 2025, spanning both the Rowley and Persad-Bissessar administrations. Both deserve credit. The PNM government introduced enabling legislation in September 2024, signed the Multilateral Convention in November 2024, and held Brussels meetings to advance the case. The UNC government completed the remaining steps after taking office in April 2025. Former Finance Minister Colm Imbert has noted that the work that put the country on the path to delisting was done under the PNM government before the April 28, 2025 election. That is partly true - and partly incomplete, since the UNC carried the process across the finish line.
The most significant legislative change was the Special Economic Zones Act, 2022, which replaced the Free Zones Act. The SEZ Act was partially proclaimed on January 31, 2022, establishing the Trinidad and Tobago Special Economic Zones Authority. Full proclamation came on July 5, 2024, formally repealing the Free Zones Act and bringing the SEZ Regulations of 2023 into effect. The new framework introduced greater transparency, economic substance requirements, and a regulatory structure aligned with OECD and EU standards. Enterprises previously granted benefits under the old Free Zones Act were given a transition period through December 31, 2024.
On November 7, 2024, then-Finance Minister Colm Imbert signed the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters at OECD headquarters in Paris, making Trinidad and Tobago the 149th jurisdiction to participate. The convention entered into force on April 1, 2025. Imbert also signed the Multilateral Competent Authority Agreements for automatic exchange of information under the Common Reporting Standard and on Country-by-Country Reports.
In mid-2025, the Global Forum released its Second Round peer review of Trinidad and Tobago, upgrading the country's rating from its earlier non-compliant status to "Largely Compliant." The review acknowledged that while the current legal framework was considered robust, further efforts were needed on effective implementation - particularly in monitoring and supervision of accounting obligations and the practical functioning of the exchange-of-information framework.
Finally, the government strengthened its Anti-Money Laundering and Counter-Financing of Terrorism infrastructure, enacting legislation on beneficial ownership transparency, expanding asset-recovery tools, and tightening controls on virtual-asset activities. Together, these reforms addressed all three of the EU's assessment criteria: tax transparency, fair taxation, and implementation of BEPS standards. The Council's February 17 decision followed.
The Correspondent Banking Cascade
The most significant cost of the EU blacklist was never a fine or sanction imposed by the EU itself. It was the effect on correspondent banking relationships - the connections between Trinidad and Tobago's domestic banks and the international banks that process cross-border transactions.
When a country appears on the EU's non-cooperative list, international banks increase their compliance scrutiny on transactions involving that country. This triggers a cascade that is disproportionate to the listing itself. Additional due diligence requirements are imposed. Processing times lengthen. Transaction costs rise. And in some cases, correspondent banking relationships are terminated outright - a process known in the financial industry as de-risking.
The Caribbean has been particularly affected by de-risking. A 2017 survey by the Caribbean Association of Banks found that 21 of 23 banks across 12 Caribbean countries had lost at least one correspondent banking relationship. Saint Vincent and the Grenadines, the Bahamas, and Jamaica each lost more than 40 per cent of their correspondent banking connections. Trinidad and Tobago was among the countries affected, though Republic Financial Holdings - the largest indigenous financial group in the region - maintained its relationships, in part because of its own robust AML compliance standards.
For Trinbagonian businesses that import goods, pay international suppliers, or receive payment from overseas customers, these pressures were real and compounding. The Trinidad and Tobago Chamber of Industry and Commerce published a detailed survey in December 2025 that documented the scale of the problem. Some 62 per cent of businesses reported delays in paying suppliers. Nearly 60 per cent reported declining profitability linked to forex shortages. Over a third of respondents waited more than four weeks for foreign currency requests to be fulfilled. Smaller companies and those that do not generate their own US dollars through exports faced delays of three to nine months.
The forex crisis is not solely attributable to the EU blacklist. The structural overvaluation of the TT dollar, declining energy revenues, and the Central Bank's managed exchange rate all contribute. But the blacklist made everything worse. It layered additional compliance friction onto a system already under severe strain.
The European Chamber of Commerce documented the impact on foreign investors specifically. Companies considering Trinidad and Tobago faced additional due diligence requirements from their own banks and compliance teams. The blacklist did not prohibit investment - but it added friction, and in a competitive environment where neighbouring jurisdictions were actively courting the same capital, friction drives money elsewhere. As TEMPO Networks noted in its February 2026 analysis, capital flows are increasingly tied to regulatory certainty. Markets that take eight years to adapt absorb the cost in foregone capital.
The reputational dimension compounds the financial one. Being listed alongside jurisdictions known for opacity sends a signal embedded in risk databases, automated screening tools, and compliance algorithms worldwide. Removal from the EU list is a necessary correction, but institutional memory is long.
The Recovery Timeline
Removal from the EU list is the necessary first step. It is not the last.
Correspondent banking relationships that were terminated or downgraded during the listing period do not automatically resume. Banks that cut ties will need to be re-engaged individually. The IMF's February 2026 Article IV Mission noted that while the banking sector appears sound and well-capitalised, the broader challenge of ensuring effective implementation of the new transparency framework remains.
The Global Forum's "Largely Compliant" rating, while a major improvement over 2011, is itself a signal that work remains. The peer review identified gaps in the practical functioning of the exchange-of-information framework - delayed responses, partners not informed about request status. These are the operational details that determine whether international counterparts trust the system.
The next revision of the EU list is scheduled for October 2026. Trinidad and Tobago will need to maintain its reforms and demonstrate continued compliance to avoid being re-listed. The Turks and Caicos Islands were added back to the blacklist in the same February 2026 update that removed Trinidad and Tobago - a reminder that delisting is not permanent.
The Cost of Delay
The reforms that secured the delisting - the SEZ Act, the OECD convention, the Global Forum improvements, the AML/CFT legislation - are genuine structural changes. They improve the country's position regardless of the EU list. They were also, for the most part, achievable years earlier.
The Free Zones Act could have been replaced sooner. The OECD convention could have been signed sooner. The transparency framework could have been upgraded sooner. Every year those steps were not taken was a year of accumulated cost that businesses absorbed in higher transaction fees, longer forex delays, lost banking relationships, and deferred investment.
That cost has not been calculated by any government agency. It should be. Not as an exercise in blame - the listing spans two administrations - but as a measure of what institutional delay actually costs a small open economy. When compliance with international standards is treated as a low-priority bureaucratic exercise rather than an economic imperative, the bill is paid by every business that could not get forex on time, every investor who chose a compliant jurisdiction instead, and every worker whose job depended on a transaction that took six months instead of six days.
The delisting is worth celebrating. The cost of the delay is worth accounting for. Both things can be true.
Sources
- EU Council: "Taxation: Council updates the EU list of non-cooperative jurisdictions for tax purposes" (February 17, 2026) - consilium.europa.eu
- EU Council: Timeline - EU list of non-cooperative jurisdictions - consilium.europa.eu
- European External Action Service: "Trinidad and Tobago Removed from EU Tax List" - eeas.europa.eu
- OECD: "Trinidad and Tobago joins Multilateral Convention to tackle tax evasion and avoidance" (November 7, 2024) - oecd.org
- OECD: Global Forum on Transparency and Exchange of Information for Tax Purposes: Trinidad and Tobago 2025 (Second Round) - oecd.org
- Ministry of Finance: "Trinidad and Tobago has joined the World's Widest Reaching Multilateral Treaty" (November 12, 2024) - finance.gov.tt
- Ministry of Trade and Industry: "Full proclamation of the Special Economic Zones Act, 2022" (July 5, 2024) - tradeind.gov.tt
- Trinidad and Tobago Special Economic Zones Authority (SEZA): About - seza.gov.tt
- Hamel-Smith: "From Free Zones to Special Economic Zones: One step closer to international tax compliance" - trinidadlaw.com
- IMF: "Trinidad and Tobago: Staff Concluding Statement of the 2026 Article IV Mission" (February 10, 2026) - imf.org
- Trinidad and Tobago Chamber of Industry and Commerce: "Challenges in Accessing Foreign Exchange" (December 2025) - chamber.org.tt
- European Chamber of Commerce Trinidad and Tobago: "The Foreign Exchange Challenges in Trinidad and Tobago and the Impact on Foreign Investors" - eurochamtt.org
- TEMPO Networks: "EU Blacklist: What It Signals For Caribbean Investment Risk & Capital Access" (February 22, 2026) - temponetworks.com
- Caribbean Association of Banks: De-risking survey data (2017)
- CFATF: "De-Risking in the Caribbean Region - A CFATF Perspective" - bahamasamlconference.centralbankbahamas.com
- Central Bank of Trinidad and Tobago: Financial Stability Report 2024 - central-bank.org.tt
- Budget 2026 Statement - EU blacklist section (October 14, 2025)
- Trinidad Express: "T&T removed from EU Tax Blacklist" - trinidadexpress.com
- Trinidad Express: "T&T edges closer to removal from EU tax blacklist" - trinidadexpress.com
- Colibri Advisory: "Government confident of removal from EU blacklist" - colibriadvisory.com
- First Citizens Group: "Special Economic Zones (SEZs)" - firstcitizensgroup.com