AML/CFT Policy

1. Purpose

This policy establishes our framework for:

• Preventing money laundering through our platform
• Preventing terrorist financing
• Complying with international sanctions
• Protecting the integrity of humanitarian funding

2. Risk Assessment

We conduct ongoing risk assessments considering:

• Geographic Risk: Countries subject to sanctions or high-risk jurisdictions
• Transaction Risk: Unusual transaction patterns or amounts
• Customer Risk: Politically exposed persons, complex ownership structures
• Sector Risk: Humanitarian sector-specific vulnerabilities

3. Due Diligence

3.1 Know Your Customer (KYC)

For all NGO partners, we verify:

• Legal registration and incorporation documents
• Identity of directors and authorized personnel
• Beneficial ownership structure
• Source of existing funds

3.2 Enhanced Due Diligence

Additional scrutiny is applied for:

• Operations in high-risk countries
• Large-value transactions
• Politically exposed persons
• Complex organizational structures

3.3 Ongoing Monitoring

We continuously monitor transactions and relationships for suspicious activity.

4. Sanctions Screening

All parties are screened against:

• UN Security Council Consolidated List
• OFAC Specially Designated Nationals (SDN) List
• EU Consolidated Sanctions List
• Other applicable national sanctions lists

Screening is performed at onboarding and periodically thereafter.

5. Suspicious Activity Reporting

We are obligated to report suspicious activities to relevant authorities. Indicators include:

• Unusual transaction patterns
• Attempts to structure transactions
• Reluctance to provide required information
• Inconsistent documentation
• Links to sanctioned entities or persons

6. Record Keeping

We maintain records of:

• All due diligence documentation
• Transaction records
• Screening results
• Internal reports and investigations

Records are retained for a minimum of 5 years after the relationship ends or transaction completes, as required by law.

7. Training

All staff receive AML/CFT training covering:

• Recognition of suspicious activity
• Reporting obligations and procedures
• Updates on regulatory changes
• Sector-specific risks

Training is provided upon joining and refreshed annually.

8. Compliance Responsibility

Our designated Compliance Officer is responsible for:

• Implementing and maintaining this policy
• Receiving and investigating internal reports
• Filing reports with authorities
• Ensuring staff training
• Reporting to senior management

9. Contact