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COMPANY POLICIES

Anti Money Laundering Policy

Ave Maria Orphanage

  1. Introduction

Ave Maria Orphanage (hereafter referred to as “the Orphanage”) is committed to preventing any involvement in money laundering or the financing of terrorism. This Anti-Money Laundering (AML) Policy outlines the steps the Orphanage will take to prevent and detect money laundering activities in compliance with relevant laws and regulations.

  1. Purpose

The purpose of this AML Policy is to:

  • Establish procedures to detect and prevent money laundering activities.
  • Ensure compliance with applicable laws and regulations.
  • Protect the Orphanage’s reputation and integrity.
  1. Scope

This policy applies to all staff, board members, and volunteers of the Orphanage.

  1. Definitions
  • Money Laundering: The process of concealing the origins of illegally obtained money, typically by transferring it through a complex sequence of banking transfers or commercial transactions.
  • Terrorism Financing: The act of providing financial support to terrorist activities or organizations.
  1. Responsibilities
  • Executive Director: Oversees the implementation of this policy and ensures compliance with AML regulations.
  • Finance Manager: Monitors financial transactions, conducts due diligence, and reports suspicious activities.
  • All Staff: Must adhere to the AML Policy and report any suspicious transactions or activities.
  1. Due Diligence
  • Know Your Customer (KYC): The Orphanage will verify the identity of donors, partners, and stakeholders through reliable and independent sources before engaging in any financial transactions.
  • Risk Assessment: Regular risk assessments will be conducted to identify potential money laundering risks associated with different financial activities.
  1. Record Keeping
  • Documentation: The Orphanage will maintain comprehensive records of all financial transactions, donor information, and due diligence procedures for a minimum of five years.
  • Access: Records will be securely stored and accessible only to authorized personnel.
  1. Monitoring and Reporting
  • Transaction Monitoring: Financial transactions will be monitored for unusual or suspicious patterns that may indicate money laundering activities.
  • Suspicious Activity Reporting: Staff must report any suspicious transactions or activities to the Finance Manager, who will then report to relevant authorities if required.
  1. Training and Awareness
  • Training: All staff will receive training on AML procedures, including recognizing and reporting suspicious activities.
  • Updates: The AML Policy will be reviewed and updated regularly to reflect changes in regulations and best practices.
  1. Policy Review

This AML Policy will be reviewed annually and updated as necessary to ensure ongoing compliance with applicable laws and regulations.

  1. Compliance

Failure to comply with this AML Policy may result in disciplinary action, including termination of employment or volunteer status. The Orphanage will cooperate fully with law enforcement and regulatory authorities in the investigation of any suspected money laundering activities.

  1. Contact Information

For questions or concerns related to this policy, please contact:

Executive Director
Ave Maria Orphanage
Email: letstalk@theforgottenneighbor.org
Phone: +256762827661

Finance Manager
Ave Maria Orphanage
Email: finance@theforgottenneighbor.org
Phone: +256703454919

Date of Adoption: August 24, 2024
Effective Date: August 24, 2024