Is it a requirement of the COC for charities to have an Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) policy?
Charities are attractive conduits and can be at risk of abuse for money laundering (ML) and terrorist financing (TF). Such ML/TF abuse could take various forms, including being used as a conduit for movement of illicit funds. Charities are more vulnerable to abuse if their financial administration practices and internal control procedures are weak and there is an absence of due diligence checks conducted on their stakeholders, including donors.
As such, charities are highly encouraged to put in place the appropriate mitigating measures, including documented AML/CFT policies and procedures, to safeguard themselves against such risks.
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