1 Purpose and scope
This policy protects the Association against misuse of funds and programmes for terrorist financing, money laundering or proliferation financing. It covers the Board, staff, volunteers, representatives and partners. Obligations specific to non-profit organisations apply; the Association is not automatically classified as a financial institution or designated non-financial business or profession.(1)
2 Governance and risk assessment
The Board names a compliance lead with access and independent escalation authority, appoints a substitute and defines resources and reporting. The regulator is consulted to establish whether a formally designated compliance officer and system registrations are required. Unresolved classification must not obstruct mandatory reporting.
Compliance assesses risks annually and when activities change, considering funding sources, regions, channels, partners, beneficiaries and products, with reasoned ratings, controls and residual risk. National assessments and regulatory guidance are considered without assuming all public-benefit activities are high risk.
3 Due diligence
Relevant parties’ identities, representatives’ powers, entity licensing, ownership and control structures and beneficial ownership are verified proportionately to risk. Funding source, purpose and expected use are examined; verification limits, documents and findings are recorded before the relationship or payment.
Unclear sources, unjustified complexity, unusual dealings or high risk require enhanced diligence, additional information, higher approval and closer monitoring. Political exposure or nationality alone is not proof of crime. An existing relationship does not remove the need for updated checks.(2)
4 Monitoring and indicators
Reviews examine transactions inconsistent with their purpose, splitting, insistence on cash or third parties, donations followed by different refund requests, and contradictory documents. Transfers are compared with beneficiaries, invoices and the programme; findings are documented. Targeted-sanctions controls apply independently of suspicion assessment.
5 Escalation and reporting
Employees immediately report indicators and evidence to the compliance lead without tipping off the party or conducting a personal investigation. The lead determines protective measures, submits mandatory external reports through the organisation’s prescribed official channel and seeks guidance if the route is unclear without delaying urgent action.
Suspicions involving the lead or Board Chair are escalated to an unconflicted substitute and, when needed, the competent authority. Reports remain confidential; retaliation and disclosure undermining examination are prohibited. Mandatory reporting does not depend on a Board vote.
6 Training, testing and records
Relevant personnel are trained on joining and annually, using role-appropriate cases. Controls are independently sample-tested and gaps closed to deadlines. Assessments, diligence, transactions and reports are retained with minimum necessary access for the longest applicable period. Destruction stops during an investigation or official request.
References in the approved document
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Federal Decree-Law No. 10 of 2025 on combating money laundering, terrorist financing and proliferation financing. This document establishes internal implementation controls without changing higher legal powers or requirements.
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Cabinet Resolution No. 134 of 2025, Article 34 on non-profit organisations; Resolution No. 5 of 2025, Article 26. This document establishes internal implementation controls without changing higher legal powers or requirements.