Letter to the Editor – Open Letter to our Finance Minister

26 Sept 2025

The Editor,

The appointment of Dave Tancoo as Finance Minister following the UNC’s electoral victory on April 28th, 2025, represents an opportunity for fresh perspectives in Trinidad and Tobago’s fiscal leadership. As Minister Tancoo prepares his inaugural budget presentation, the following strategic approaches merit consideration for strengthening the nation’s economic foundation.

Given the importance of this transition period and the complex challenges facing our economy, these three policy frameworks are offered as constructive contributions to the national dialogue on fiscal strategy and economic development priorities –

  1. Revenue Generation – At this time of decreased national earnings and steep declines in the availability of $USD, it is important to appreciate the crucial role of the Energy sector to our national prosperity. In 1974, the Permanent Petroleum Pricing Committee (PPPC) was established to combat the pernicious practice of Transfer Pricing in the Energy Industry. For reasons which remain unclear, the PPPC was effectively dismantled in the 2000/2001 period, so yet another ‘Legacy Policy’ was silently wrecked to our collective detriment, since that shift could only have benefitted the Energy Companies.  As explained over the past two decades by my peerless colleague and Energy Adviser, Anthony Paul, the fiscal losses to T&T have been tremendous. Ian Narine also highlighted this important issue in ‘Foreign Exchange and Economic Fantasies’ in the Business Guardian of 25th September 2025. It is therefore essential that the Finance Minister urgently re-instate the Permanent Petroleum Pricing Committee (PPPC) to safeguard our nation’s share of those earnings.

    In that connection, difficult as it may be for the UNC to contemplate, there must also be a sober re-assessment of its decision to repeal the Property Tax, as that was the most feasible window into significant untaxed earnings from Investment Property.
  2. Overseeing Transactions in Public Money – The Public Procurement & Disposal of Public Property Act (PPDPPA) was passed in 2015 during the People’s Partnership government, within which the UNC was emphatically the leading element. The previous PNM Finance Minister, Colm Imbert, removed 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. Those exclusions kept huge transactions in Public Money from Independent oversight, which could only be to our collective detriment. I am calling on the Finance Minister to take bold and restorative action to ensure the urgent repeal of those damaging exemptions from the PPDPPA.
  3. Firm action against White-Collar criminals – I smiled while reading about Finance Minister Tancoo’s clarity on the recent Financial Action Task Force (FATF) bill –
    “…Tancoo highlighted measures criminalising bribery in public procurement and embezzlement of public resources […] ‘T&T must never again find itself in the position we were in over the last few years, when the Office of the Procurement Regulator, the Auditor General, and others sounded the alarm,’ he said. ‘Billions of taxpayers’ dollars were spent illegally on projects no one could verify.’ He added that the bills establish a robust legislative framework to address crime, cross-border activities, and white-collar offences that have already cost the nation billions and affected thousands of lives. ‘We promised the people we’d tackle these issues. With these bills, that promise is kept…’

    So far so good, in relation to those international obligations, but we also need to see an equal determination to seek the Public Interest with local contractors, advisers, and suppliers. Given its position on FATF, the Finance Minister needs to ensure stern and prompt prosecution of White-Collar Crime up to and including those accused from within the UNC ranks. No more backsliding or late filing, case not ready or any of that, let these accused face the Courts and ‘tell it to the Judge’.

If UNC wishes to do better than the previous PNM administration, they must act differently.

Afra Raymond
afraraymond.net

Letter to the Editor – Public Procurement Progress?

Fri, 12 Sept 2025

The Editor,

The second Procurement Compliance Plus (PC+) Lab on 10th September 2025 was focused on Procurement Governance, so it was a strong addition to this excellent training series for this important new legal arena. Although Procurement and Purchasing are long-established essential processes for any business, this is a novel field due to the significant changes arising from the Public Procurement & Disposal of Public Property Act (PPDPPA) 2015. The PPDPPA established effective new rules to oversee transactions in Public Money, with heavily punitive provisions, its most important feature being that oversight and penalties are now applicable to both named Public Sector Officials and Private Sector Suppliers and Contractors.

The interactive sessions were hosted by a cadre of outstanding professionals, led by the estimable Dr Margaret Rose, a long-time campaigner and educator in this field. I was a panellist, but it was also an opportunity for me to learn from and engage with a range of practitioners in this multi-faceted professional field.

The PPDPPA established the Office of Procurement Regulation (OPR) as the Statutory Oversight Agency with responsibility to ensure that these transactions are conducted in accordance with that law. Public Bodies and their Private Sector counterparts will continue to contract with each other, but in this new arrangement all of those decisions are under the oversight of the OPR.

Given the importance to our Public Interest of maximising the value obtained for every dollar of Public Money, the complexity of the PPDPPA with its various intersections with other laws, the heavy penalties and the high political stakes, there is every good reason for the professionals engaged in this arena to support this outstanding series of educational conferences.

I am also told that the OPR was invited to deliver the keynote speech at the inaugural PC+ event on 2nd May 2025, so I am very disappointed that the OPR has not attended either of these pivotal conferences. I am reliably informed that the OPR declined that invitation due to a stated fear of being accused of conflict of interest, given that it is that office which would have to rule on any complaints, challenges or other disputes. I will not stand aside while the OPR becomes yet another of our ineffective Oversight Bodies, like the Auditor General or the Integrity Commission. There is simply too much at stake here.

Apart from the over-arching point that the OPR could participate in such events without any loss of its neutrality, impartiality or fairness and more importantly, would certainly gain tremendous understanding of the challenges facing practitioners. All in all, the further bonus from OPR participation in these events would be a far greater general understanding of the issues and their context. The OPR must urgently reconsider its reluctance to attend these PC+ events, especially since its reasons appear quite rickety when one considers that  the Chief Justice gave the keynote at the inaugural event and there were three Appeal Court judges in attendance at the entire second event.

Justice and its Officers should not be so cloistered and in this new dispensation that must now include Procurement Regulators.

Afra Raymond
afraraymond.net

Letter to the Editor – The State-owned and controlled entities

Sunday, 31st August 2025

The Editor,

The April 2025 election of the UNC govt has triggered convulsions within State-controlled entities, with the replacement of Boards and Management being the main issues, most recently in the case of First Citizens’ Bank (FCB) in which the State is the majority shareholder.

The Finance Ministry is entirely within its legal rights to change the Boards of State-controlled entities, subject of course to compliance with the Central Bank’s ‘Fit & Proper’ rules and the requirements for an Extraordinary General Meeting. 

That said, there are a few additional perspectives to consider, flowing from the PM’s outright, repeated declarations that the State is the majority shareholder in both FCB and Republic Bank Ltd – 

  • Republic Bank’s Board – We are witness to the sudden replacement of FCB’s CEO and its entire Board, so are we now therefore to expect that the Republic Financial Holdings’ CEO and Board is to be similarly, summarily replaced? If not, why not? This question was also posed by my erstwhile colleague and Business Guardian Editor, Anthony Wilson, on 28th August 2025 in ‘Is Republic Bank next?
  • The Integrity Commission – Will all Officers and Directors of both those companies now be required to file declarations to the Integrity Commission?
  • Changing/Replacing the Board – I agree with Mariano Browne’s recent comments that it is inadvisable and extremely rare for the entire board of a financial institution to be changed all at once, since that means complete loss of institutional memory.

Finally, I was concerned to note that the new appointee as incoming FCB Chairman is Mr Shankar Bidaisee, who was also recently appointed Chairman of UDECOTT. This is not in any way an attack on Mr Bidaisee’s competence, but the era of the ‘super-Chairman’ or ‘Czar’ should be placed firmly in the history books. Former PM, the late Patrick Manning, found such favour with Calder Hart that he was appointed to Chair the Boards of five State-controlled  entities. Yes, five. We all should reflect on how that particular ‘concentration of power’ ended-up1. But that was in the ‘bad-old-days’, and we ought to have learned from those bitter experiences. There are enough high-quality, willing candidates to serve in those positions, even given the heavy demands of public office. That concentration of power is never a good thing, so it needs to be avoided.

Afra Raymond
afraraymond.net

  1. The impact of that benighted period was deep and adverse, climaxing in the Uff Enquiry which effectively unmasked Calder Hart such that he departed just before publication of that Report, never to return – two decisive extracts from Hart’s cross-examination are here for readers who want to see the pitiful depths to which racism and colonialism took us in the first decade of the new millennium, under a PNM administration. ↩︎

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 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”

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/.

Letter to the Editor – Come Again, Minister West

The Editor,

The Minister of Public Administration [MPA] responded to my previous letter in the Sunday Edition of 29 October 2023, the very next day.

TTT Live Online

Minister West disputed my citations of the monthly rent of $600,000 and the 23,000sf floor area of those offices, as well as my conclusion that the resulting rent of $26psf signified ‘flagrant corruption’.  The Minister went on to say that the correct monthly rent was $500,000 and that the floor area was in fact 43,295sf, which equates to a rent of $11.55psf.  

As I indicated in the previous letter, my figures were drawn from both the PM’s public statements and the immediately subsequent Express article.  The PM emphatically stated the monthly rent to be $600,000 at the post-Cabinet Media Briefing on Thursday 23rd March 2023 and the 23,000sf floor area is in that Express article of 11 March 2023 – $40M SPENT ON NEW DPP OFFICE – but I have not been able to establish any other source for that citation.

Start 06:24, End 11:46

Minister West gave no citations in support of the claimed figures and I reject entirely the unstated position too often taken by our rulers that “if I say so, is so.”  I gave my citations, so given that MPA is relying upon the Lease and Valuation Report for this property to challenge my citations, those documents should be published now, to “show us their workings.”

Of course, if the State was able to rent those high-quality Park Court offices at $11.55psf, I have no difficulty in accepting that as a commendable negotiation outcome, notwithstanding the other aspects which have stirred public concern on this matter.

The AG told the Standing Finance Committee of Parliament on 19th October 2023 that the Public Money spent on that property was $55,551,443.93  (at 4:49:45).  Given the understandable and widespread public concerns arising from this large-scale expenditure, it would be an important step towards transparency for the MPA to issue details of how those monies were spent.  The $500,000 monthly rent stated by Minister West would amount to $19.0M over the three years and two months that property was leased.  The cost of the improvements and modifications has repeatedly been stated as $24M.  The total of those two figures is only $43M, so I have certain concerns.  I am sure that a statement clarifying those details can be quickly issued.

Finally, this entire issue of the wasted Public Money on these offices which were never occupied is rooted in the requirement for a proper Needs Assessment before committing to any Procurement.  If a Needs Assessment was done in this matter, there is certainly good reason to re-examine that process to ensure that we avoid such waste in the future.

The Minister also mentioned that these details are available on the ‘Property & Real Estate portal’ at https://pmis.gov.tt/, but this as yet inaccessible to the public.  Why not make the entire database readily accessible to the public, just like the EBC list?  

Afra Raymond
afraraymond.net