What should my charity include in the AML/CFT policy? Does the COC have any template/guidance on this?
An AML/CFT policy should minimally include procedures for due diligence checks, on-going monitoring of programmes and usage of funds, financial accountability, and transparency as well as reporting of suspicious transaction identified during your charity’s operations.
Charities can reference the Terrorist Financing Risk Mitigation Toolkit for Charities, in particular Appendix D, for the recommended mitigating measures for AML/CFT.
Charities can also apply for grants under the Charities Capability Fund, which provide partial funding for charities that wish to engage consultants to draft AML/CFT policies and procedures and/or to attend relevant training.