Introduction
ASHM embraces a risk based approach to managing compliance, ensuring adequate controls are
implemented to combat, detect, and report potential money laundering and financing terrorist
activities.
As at August 2017 AUSTRAC and the Australian Charities and Not-for-profits Commission (ACNC)
assess Anti-Money Laundering (AML) and Counter Terrorism Financing (CTF) risks affecting Australian
NGOs as Medium (this assessment remains valid for this 2024 policy review). This is primarily based
on suspicious matter reporting, the number of investigations into predicate crimes involving Not For
Profits (NFPs), and anecdotal insights from sector representatives regarding levels of criminal
exploitation.
The key threats facing the NFP sector are fraud and theft of resources. General factors that increase
any NFP’s vulnerability to money laundering or terrorism financing include:
- poor understanding of the risks of money laundering and terrorism financing
- poor due diligence on key personnel, volunteers, partners and beneficiaries
- inexperienced staff
- lack of formalised training and ongoing professional development
- poor record keeping
- weak internal controls
- poor transparency and accountability of the end-to-end funding cycle
- beneficiaries or operations in countries with poor AML/CTF regimes
- beneficiaries or operations in conflict or post-conflict regions
- beneficiaries or operations in dispersed ethnic communities in Australia, with strong links to
high-risk countries (specific to terrorism financing only).
Purpose
The purpose of the Policy is to confirm ASHM’s commitment to dealing with AML and CFT risk and to outline the key rules that underpin this commitment.
Definitions
Money Laundering is the process of concealing the existence, illegal source, or application of income
from criminal activity and the subsequent disguising of that income to make it appear legitimate.
Money laundering is just as serious as the underlying crimes that generate the money that is
laundered.
Terrorism financing refers to activities that provides financing or financial support to
individual terrorists or terrorist groups.
Vulnerability refers to the characteristics of a sector that make it susceptible to money laundering
(including criminal misuse) or terrorism financing.
Consequence refers to the potential impact or harms of money laundering and terrorism financing in
the NFP sector. It involves consequences for NFPs, individuals, national and international security, and
the Australian economy and community
Policy
ASHM staff, board members, contractors, suppliers, volunteers and implementing partners are
subject to counter terrorism checks.
Checks will be performed against the Criminal Code list of terrorist organisations and the DFAT
consolidated list of individuals and entities subject to targeted financial sanctions, as per the
following:
Asian Development Bank Sanction list
Attorney General’s Department List of Terrorist Organisations
World Bank Listing of Ineligible Firms
The lists are consolidated in the screening software we use for running the checks called “LexisNexis”.
The following are subject to mandatory terrorism checks against the lists above:
- All staff, board members, contractors, suppliers, volunteers of ASHM
- Partner organisations, their board members, staff, suppliers and partners involved in
ASHM global projects.
- Checks are to be completed prior to recruitment of a new board, staff member,
contractor, volunteer, supplier and implementing partner and on an annual basis in July
each year.
ASHM generally receives funding from government bodies, well known international agencies or companies with which it has previously done business. Any money received from sources that do not fit this profile will be investigated in accordance with acknowledged Australian Government ‘Know Your Customer’ procedures.
All checks against prohibited entity listings will be documented.
ASHM will maintain strong controls over its expenditure, as documented in its Fraud Management and Segregation of Duties policies, to ensure we know where funds are being dispersed and that payments related to approved activities are supported by a contract which has undergone due diligence processes.
Finance staff are trained on AML/CTF risks and threats to assist in identifying any unusual
transactions.
Any unusual activities, receipts or payment requests which might indicate AML/CTF activity will be escalated immediately to ASHM CFOO and thence to relevant regulatory bodies for further investigation.
ASHM will adhere to any AML/CTF directives imposed on it by relevant regulators.
ASHM performs police checks on all new employees.
Whilst ASHM provides services in countries with poor AML/ CTF regimes, all staff are based in Australia and the supervision and management of all service contracts, as well as its banking and finance operations, are performed in Australia.
Any incidents or suspected incidents will be reported to the senior management team following the
Incident Report Framework located in the Risk Management Policy.