Letter to the Editor – Repeal all Exclusions/Exemptions to the Public Procurement & Disposal of Public Property Act NOW

15th August 2025

The Editor,

Since the UNC’s election victory on 28 April 2025, we have had several official statements on allegedly excessive legal fees paid by the State during the previous PNM administration from 2015 to 2025.

Some details of those legal fees paid have now been published, which is good, since transparency on the expenditure of Public Money is essential if we are to have an informed engagement with these issues.

The ongoing ‘CEPEP case’ is also a serious concern, as the parties appear to be battling over the existence and content of various Cabinet Notes and Board Resolutions, not to mention who said what to who and WhatsApp messages and so on. At issue is the legitimacy/legality of the April 2025 renewal/award of various CEPEP contracts said to total $1.4 Billion in Public Money. Having read those articles, I am staggered that the reported defence of the ex-CEPEP Chiefs does not seem to be citing their compliance with the Public Procurement and Disposal of Public Property Act (The Act). What is more, the plaintiffs, as reported in the press, also seems to be silent on such compliance, which is what is required by The Act since April 2023. As interesting as those reported details are, the decisive point in this matter is CEPEP’s compliance with the Act in awarding those contracts.

In the ‘bad-old-days’ of the previous PNM administration we saw the then-AG, Faris Al Rawi, making a meal of the serious allegations of massive legal fees fraud against former PP AG Anand Ramlogan SC and newly-appointed NGC Chairman, Gerald Ramdeen – the sum allegedly mis-appropriated was in the $1.0 Billion region. Yet, at the very same time, the then-Finance Minister, Colm Imbert, was exempting expenditure on legal fees from the oversight of the Office of Procurement Regulation (OPR). Incredible, but that is what really happened in this country.

I am referring to the fact that on Friday 4 December 2020 our Parliament passed the third set of amendments to the Act. Those exemptions were a serious blow to the long-term campaign for proper control over transactions in Public Money and are extremely detrimental to the public interest.

The removal of legal, accounting/auditing, medical fees, and financial services, as well as Government to Government Agreements and ‘such other services as the Minister may, by Order, determine’ from OPR oversight was risible when one considers the strong and repeated statements as to concerns over the alleged legal fees and other scandals. The over-stated concerns as to speed and efficiency could have been addressed by approval limits for ‘Procuring Entities’ and an obligation to make quarterly reports to the OPR. At that time, it was remarkable that the Opposition UNC, as it then was, seemed unable (or was it merely unwilling?) to make those points or advance any counterproposals.

We now have a freshly elected government, with its AG making loud claims about excessive legal fees paid by the previous PNM administration, with a troubling silence on the UNC position on those damaging 2020 exemptions from the Act. I am not at all inspired by the disclosure of this or that legal fee, since what we need is a clear position from the UNC on the repeal of those damaging exemptions from the Act. Those detrimental exemptions must now be repealed so that the public interest could be well-served by comprehensive and independent oversight by the OPR, as intended when the People’s Partnership (PP), of which the current ruling UNC was the leading element, passed the parent legislation – Act No 1 of 2015.

We must avoid the errors of the past if we are to do better. If the newly-elected UNC govt wishes to do better, it must act differently from the previous PNM govt. It would be a serious blow to our Republic if the OPR were to become yet another toothless/ineffective oversight body, like the Integrity Commission or the Auditor General.

Afra Raymond
afraraymond.net

Letter to the Editor – Publish details of State Office Rentals NOW!

The Editor,

In the early 2000s, the then-PNM administration, under the late Patrick Manning, made ambitious urban development proposals intended to reduce the State’s historic dependence on private-sector landlords. 

That program was executed by UDECOTT, under the hand of Calder Hart, with 2.3M square feet of offices constructed by the State in POS. The iconic, elliptical, blue-glass office tower on Independence Square is Nicholas Towers, which contains 100,000 sf of offices – so our Public Money funded the construction of new offices 23 times the size of Nicholas Towers. 

Apart from the staggering UDECOTT corruption confirmed at the 2009 Uff Enquiry, I have always had nagging doubts as to whether that massive office construction program actually achieved its objectives. Despite my efforts, it was never clear if our monthly rental bill for State offices had in fact been significantly reduced as a result of that UDECOTT program. There certainly have been no official declarations of that achievement, which one would expect if indeed that had been the case, given our political culture.

In October 2023, I exchanged points with then Public Administration Minister, Ms Allison West, on the conflicting and incomplete details of the State’s leasing of the former RBC HQ building at Park St in POS for the Office of the DPP. At that time, then-Minister West attempted a rebuttal of my claims of massive corruption, but that was rendered nugatory by both her failure to provide any substantiation for the details of the Public Monies spent on that failed project and her claims that all the details of State leases were available on the ‘Property & Real Estate portal’ at https://pmis.gov.tt/. That link remains a dead one, so the information is as yet inaccessible to the public. At that time, I asked the question – 

‘Why not make the entire database readily accessible to the public, just like the EBC list?’.

There was no reply, so no details were provided.

I was therefore pleased to hear the statement by Prime Minister Kamla Persad-Bissessar SC to the 22nd May 2025 post-Cabinet Press Briefing in which the issue of secrecy/confidentiality of State office rentals was specifically addressed – 

“…We will release the existing list to the Public, in the interest of Transparency…this is your Money, this is Taxpayers’ Money, and you have a right to know where your Money is being spent…So Minister has been given the authority to release that list of the rentals, for you to see what has been happening, in secret and, in some cases, illegally…if public members don’t want people to know that we are renting your building, Government is renting your building, with Taxpayers’ Money, then too bad for you, don’t rent-out your building, do not rent-out your building if you don’t want people to know that you are renting your building to the Government…simple as that, so don’t come and cry and plead ‘privacy’, there is no privacy when we are spending Taxpayers’ Dollars…there can be no defence of ‘Privacy’, or you don’t want your name out there…” 

The PM’s statement can be found between 13:22 and 14:48 in the YouTube recording of that 22nd May 2025 post-Cabinet Press Briefing.

I entirely agree with those emphatic statements from our PM, Kamla Persad-Bissessar SC, so I am calling for all the details of the State’s office leases to be published as a searchable database showing Addresses: Owners’ identities: Square footage: Carparking: Rental paid: Lease terms (i.e. start and finish dates): Repairing/Maintenance obligations.

Sunlight is the best Disinfectant.

Afra Raymond
afraraymond.net

Letter to the Editor – Publish the Colman Report into the collapse of CL Financial NOW

July 25, 2025
The Editor,

Some nine years after its completion, we now need to have the Colman Report into the collapse of the CL Financial Group published.

The bailout of the CL Financial Group (CLF) started in January 2009 and consumed over $25 Billion in Public Money, in circumstances which remain mostly unclear, even after a full-scale Commission of Enquiry into the collapse of both CLF and the Hindu Credit Union (HCU), conducted by the late Sir Anthony Colman QC.

That Commission of Enquiry was ordered by the PP govt, led by Kamla Persad-Bissessar, which marked a welcome spell of lucidity in that troubled period of growing financial turmoil. The 2010 budget speech by then Finance Minister Winston Dookeran (pgs 342 to 345) gave the required clarity and purpose to the proper understanding of the CL Financial collapse and the consequent bailout, which he was proposing to re-order. Then PM Kamla Persad-Bissessar’s speech on 1st October 2010 (pgs 19 to 34) made irrefutable points on the mishandling of the bailout and proposed the Commission of Enquiry.

This Season with the two-month transition from Emancipation Day on 1st August to Independence on the 31st of August, then onto Republic Day on 24th September is one of sober reflection and re-dedication for me. It seems to me that the very sequence of events and the consequent holidays in the season imbue it with an inner meaning about national transition to some kind of depth and purpose, but maybe that is just sentimental of me, we will see.

This Season of Reflection beckons yet another Sankofa Moment in which I will contemplate our past efforts so as to better understand our future. 

Colman’s Report was completed in two parts – 

  • the HCU part was published by the PP govt to its immense credit, immediately upon its completion, in July 2014;
  • The CL Financial part was completed at the end of June 2016, but the PNM govt did not publish that Report, citing the DPP’s reported concerns that doing so would imperil any future prosecutions – viz then-PM Dr Keith Rowley’s address to Parliament on 1st July 2016 (pgs 193 to 199).

Nine years have now passed, with no reported arrests, charges, prosecutions or asset seizures. I have repeatedly requested an update from the DPP, but that is that.

The newly elected UNC govt, under Kamla Persad-Bissessar SC, has promised to publish the Colman Report into the collapse of CL Financial and I have no reason whatsoever to doubt that commitment, given their estimable performance on this issue. I am calling for that Report to be published now.

Afra Raymond
afraraymond.net

Letter to the Editor on proposed restart of Tobago Sandals talks

Friday 4th April 2025

To the Editor,

Following Dr. Rowley’s statement on 15th March 2025, we now know from our newly-selected Prime Minister, Stuart Young SC, that Adam Stewart, Executive Chairman of Sandals, is scheduled to visit Tobago on Monday 7th April 2025 to resume discussions on the Tobago Sandals project.

According to PM Young, “We need to learn from the mistakes of the past, and not allow a few misguided naysayers to stop the potential development of the economy of Tobago. This is for Tobago.”

In response to Dr Rowley, THA Chief Secretary Farley Augustine remarked, ‘‘…Tobagonians rejected the Sandals project because it was undemocratic and did not make proper economic sense, that MoU that was signed by the current MP for Tobago West (Shamfa Cudjoe-Lewis) and it did not meet the environmental best practices or standards that we wanted…” (The emphasis is mine, as I entirely agree with those comments.)

This is the same Government that resisted all attempts to release that MoU, even as Dr. Rowley and Stuart Young repeatedly insisted there was no secret agreement. Sandals itself joined that refrain until my lawsuit under the Freedom of Information Act forced the disclosure of that troubling document.

If we are to truly “learn from the mistakes of the past,” we must confront the fact that the MoU contained highly unbalanced commercial terms, so advantageous to Sandals that one wonders whether proper legal and financial advice was ever taken. In my professional view, it remains the most one-sided agreement I’ve seen in this sphere. No surprise that Sandals officials were beaming in every photo until the MoU became public and I explained its implications. At the January 15, 2019, press conference announcing Sandals’ withdrawal, both CEO Gebhard Rainer and Stuart Young looked markedly less cheerful. As always, sunlight is the best disinfectant.

The MoU obligated the State to design, build, furnish, and fit-out the resort at public expense and on publicly-owned land. Beyond that, Sandals was to enjoy unlimited work permits for non-nationals, sweeping tax holidays, duty concessions, and even facilitation of transfer pricing.

Considering that the full financial burden was to be borne by the State and Sandals was to carry no financial obligations, not even local employment, it is entirely fair to ask: what was in this for us?

This was an exploitative arrangement by any reasonable standard. Any new agreement must reflect a significantly improved balance in the national interest. Unfortunately, my expectations remain low, given that the original promoters, Dr. Rowley and Stuart Young, have never defended the terms of that flawed proposal.

I have long called for an open, transparent approach to large-scale projects, including widespread public and stakeholder consultation before commitments are made. This principle remains unfulfilled.

This concern was clearly articulated as Recommendation 17 of the Uff Report (2009):

“User groups and other interest groups should be properly consulted on decisions regarding public building projects, to ensure that relevant views can be expressed at the appropriate time and taken into account before decisions are made.” (My emphasis)

In addition, projects of this scale demand open-book accounting to safeguard the public interest.

It is also important to emphasise the environmental and social risks inherent in a project of this scale. The originally proposed site at No Man’s Land is a Ramsar-listed wetland and coastal zone, which raises serious questions about ecological sensitivity. While it is unclear whether the same location is being reconsidered, there has been no public disclosure on this point. Related stakeholders — including those in environmental management and technical consultancy — have privately expressed significant concerns about the weakening or bypassing of environmental safeguards in this process. Issues such as the treatment and disposal of wastewater, the outfall from a potential desalination plant into shallow coastal waters, and the disruption to local ecosystems remain unresolved. These concerns are not peripheral, they are fundamental. A resort development on this scale must meet rigorous environmental standards, not circumvent them.

If the State is again expected to fund this mega-project, then Sandals must contribute appropriately—paying proper taxes and fair wages. Tax holidays and concessions are indefensible if public funds are underwriting the entire enterprise.

As stated at the outset, there must be extensive public and stakeholder consultation before decisions are made. That is fundamental in any democracy.

Afra Raymond
Managing Director, Raymond & Pierre Ltd,
Chartered Valuation Surveyors, Real Estate Agents and Property Consultants

JAMP Citizen Perspectives: Fighting Corruption via Parliament webinar: 1 April 2025

JAMP Citizen Perspectives: Fighting Corruption via Parliament webinar: 1 April 2025

JAMP (Jamaica Accountability Meter Portal) presented the findings of its citizen survey on parliamentary accountability in the fight against corruption. Afra Raymond was invited to be a guest speaker at this webinar hosted by Jeanette Calder, Executive Director, JAMP, to give a Trinidad and Tobago perspective on accountability and transparency. Video courtesy JAMP

  • Programme Length: 00:32:09
  • Programme Date: 1 April 2025

No tax holiday for Sandals – Trinidad and Tobago Guardian

The T&T Guardian newspaper interviewed Afra Raymond on the issue of the renewed engagement of the Sandals hotel group to develop a resort in Tobago. The following article, written by Andrea Perez-Sobers and published on Friday, April 4, 2025, is presented below. Click here to read the complete article on the Trinidad and Tobago Guardian website.


If the State is to revisit and fund the Sandals mega-project in Tobago, the hotel must pay proper rates of tax and rates of pay to its staff.

There ought to be no tax holidays or concessions if the entire complex is to be funded by public money and on publicly owned land.

That’s according to former head of the Joint Consultative Council (JCC) Afra Raymond, responding to former prime minister Dr Keith Rowley’s statements on March 15 that he has personally reached out to the Sandals’ owner with a plea to take another look at the island.

“I didn’t give up after all that (first failed attempt). Recently, I spoke to the leadership at Sandals, and I asked them to come look at this again, and if I was the problem, I wouldn’t be there moving forward,” Rowley said, at the commissioning of Tobago’s new terminal of the ANR Robinson International Airport..

Continue reading “No tax holiday for Sandals – Trinidad and Tobago Guardian”

PROPERTY MATTERS – the role of the Valuation Roll

The implementation of the controversial Property Tax is now underway in Trinidad and Tobago, marked by a series of official announcements and the issuance of revised Notices of Valuation to an estimated 400,000 residential taxpayers. While these revisions are necessary, there is a critical flaw in the system that must be addressed: the restricted access to the Valuation Roll database. This column explores the implications of this restricted access, argues for the necessity of transparency, and identifies who stands to gain from maintaining the status quo.

The new Property Tax system in T&T aims to deliver equitable taxes through a crowd-sourcing approach, which promises transparency and low operational costs. Property owners were asked to submit detailed returns – about 60,000 of which were sent – which were then analyzed by the Valuation Division of the Finance Ministry. Selected properties were inspected and measured, leading to provisional tax assessments. Taxpayers have the right to object to these assessments, which would be refined through this iterative process of public feedback, ensuring fairness and accuracy.

Continue reading “PROPERTY MATTERS – the role of the Valuation Roll”

Keynote address to Regional Compliance Consultants Breakfast Seminar

Afra Raymond’s keynote speech at the 11th Anniversary Breakfast Seminar for Regional Compliance Consultants (RCC) held at Courtyard Marriott in Port of Spain on Wednesday, 22 May 2024. He spoke on the theme “The Importance and Ethics of the Compliance Profession”. The master of ceremonies was Kingsley Lewis of RCC.

  • Programme Date: 22 May 2024
  • Programme Length: 00:20:54
Courtesy RCC

A worthy NGO?

‘…We are not Serious…
Very few Conscious…
So I cannot agree with mih own Chorus!…’

from the first verse of ‘Dis Place nice’ by Brother Valentino

‘…Your silence will not protect you…’

Caribbean Philosopher Audre Lorde, on the false beliefs and toxic consequences earned from calculated or cowardly silences

“Last call to all corporates. Support this worthy NGO if you can,” was the rallying note from an erstwhile Colleague who had served on the Board of the T&T Transparency Institute (TTTI). This was an appeal to boost ticket sales for the TTTI’s fundraising dinner carded for 22 May 2024, but it ultimately provoked me into making these pointed observations, so here goes.

For a some years now, it has become increasingly clear that TTTI had drifted from its purpose with less and less work, of lower and lower quality, emerging from that NGO of which I am an Ordinary Member. One can scarcely believe that this was once a vibrant, outspoken and well-informed NGO with dedicated leaders such as Victor Hart, Richard Joseph, Deryck Murray and Annette des Iles, not that we can ever forget the recently departed Reginald Dumas and Boyd Reid.

I am making serious alIegations, so let me show the extent to which the TTTI has strayed from its purpose. Apart from its bewildering silence and lack of support during the recent campaign to have the Public Procurement & Disposal of Public Property Act proclaimed, one can scarcely recall the last time any TTTI Representative was on TV, Radio or in the printed Press.

TTTI’s webpage offers a June 2021 item as the latest in its ‘Press & Media Releases’ tab (almost three years ago), with its latest ‘News’ item being the January 2024 ‘Launch of the 2023 Corruption Perceptions Index’, to which I will return.

TTTI’s IG account seems to have been captured by fete-promoters, with scandalous content, which I notified TTTI about since early December 2023, but the contents are still there. [N.B. The account, with 2 posts and 10 followers to date, is online.]

TTTI’s FB page is moribund with not one single local issue highlighted in the whole of 2023 (!);

On Twitter, TTTI is also moribund (only 146 followers), with its most recent post being an anodyne International Women’s Day flyer dated 8th March 2023. The most recent local issue or event is its Town Hall meeting on 27th October 2020 against Gender-Based Violence in T&T. Clearly, both of those are important issues, but what is the nexus with TTTI’s mission?

The newly-elected TTTI Chair, Ms Donna Jack-Hill, presented the 2023 Corruption Perceptions Index on 30th January 2024 and some of her comments on the need for an independent and robust Judiciary were widely misunderstood to be pointed at T&T’s Judicial Officers. A strong backlash emerged with Press Releases from the Law Association and the Judiciary, together with several newspaper articles/editorials.

As unfortunate as it was, the misreporting of those TTTI statements and the public backlash presented a good opportunity to clear the air and for the new Chair to have reset standards. It is my view that this required a timely and solid response from TTTI, since the Press Reports on the 2023 CPI, were deeply critical of TTTI’s credibility. I am not aware that any public comment or clarification was made, so perhaps this Gala Dinner will be yet another chance to correct the record and find a new voice, albeit too long in coming. We will see.

In 100 years’ time, historians will struggle to understand how in a land like ours, an organisation like ours (yes, I am a true member of TTTI) could have said so little at a time like this.

Careerists who are concerned to bolster their CV and careful to avoid offending anyone with more power or money than themselves are a clear and present danger to our Republic, especially when they maintain an intentional silence in the face of epic wrongdoing.

Sad to say, but TTTI’s apparent reluctance to clarify or raise its voice is redolent of the evasions and strategic silences of our ruling class. Silence is the Enemy of Progress.

I welcome a response to these issues from TTTI.

Afra Raymond
afraraymond.net
This is my critique of the output of the TTTI, published on Sunday 19th May 2024 in the T&T Express, T&T Guardian and T&T Newsday, it also appeared on Wired868 – https://wired868.com/2024/05/21/dear-editor-is-tt-transparency-institute-really-a-worthy-ngo/.

Raymond & Pierre’s 50th Anniversary Land & Property mini-conference

Afra Raymond, Managing Director of property advisory company, Raymond & Pierre, speaks at the company’s 50th anniversary celebration, a mini-Conference on Land and Property in Trinidad and Tobago, hosted at the Centre of Excellence on Tuesday 13th December 2022. His first topic there was ‘Public Procurement law through the lens of professional responsibility‘. His second topic there was ‘Land & Housing Policy in post-Independence Trinidad and Tobago‘ that sees to the needs of poor people.

  • Programme Date: 13 December 2022
  • Programme Length: 00:16:02 and 00:12:38
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