AML Policy

Fundacja Independent UA, Krakow, 05/20/2022

INDEPENDENT UA takes its responsibility for ensuring the establishment and maintenance of systems of internal control for the prevention and detection of fraud, irregularities and corruption as non-negotiable and will not tolerate fraud, corruption or abuse of position for personal or institutional gain. It is therefore the policy of INDEPENDENT UA to comply fully with applicable provisions of the Proceeds of Crime Act, Terrorism Act, Bribery Act and Money Laundering Regulations and all amending legislation.

Purpose

The purpose of this policy is to ensure the charity’s compliance with anti-money laundering, bribery and corruption laws and regulations, to assist law enforcement in combating illegal money laundering, and to minimise the risk of charity resources being used for improper purposes.

Scope of the policy

This policy aims to maintain the high standards of conduct which our charity currently enjoys. This will be achieved by ensuring that INDEPENDENT UA does not get:

• used by third parties for the purpose of money laundering

• receive bribes that are intended to influence INDEPENDENT UA decision making

• is subjected to corrupt, dishonest and or illegal behaviour

This policy applies to everyone involved in the charity. i.e. employees, volunteers, suppliers, beneficiaries and the board of trustees.

This policy is made available internally throughout the charity and management is required to ensure that everyone is aware of i.

Failure to comply with this policy can lead to disciplinary action.

Money Laundering

By definition, money laundering is the practice of cleaning up money that has, for some reason, been obtained illegally. Often there is a complex trail involved so that the practice cannot be easily identified or traced.

Money laundering can occur in many ways. It may happen by dispersing money through many different bank accounts (to hide its origins), but can occur when the charity is used unwittingly as a “trading partner”. This could be directed at the charity or through an organization where we have a close relationship, such as a funder.

Due diligence

The charity should carry out procedures that help to identify donors or other providers of income before entering into a relationship or transaction with them.

The charity should, where applicable:

1. Identify the donor and verify their identity

2. Take adequate measures where some donors need or want their privacy.

3. Accept that in some cases, the identity of the donor may not be easy to verify, in which case other measures need to be developed.

4. Continuously monitor the situation and;

5. Maintain proper records of all checks made.