Anti-Money Laundering and Counter-Terrorism Financing Policy
Policies
- Code of Ethics
- Anti-Money Laundering and Counter-Terrorism Financing Policy
- Anti-Trafficking in Persons
- Anti-Trafficking in Persons Compliance Plan
- Child Protection and Safeguarding Policy
- Cookie Policy
- Donor Privacy
- Drug and Alcohol-Free Workplace Policy
- Gender Equality Policy
- Indigenous Peoples Policy
- Individual Gift Acceptance Policy
- Misconduct Reporting and Anti-Retaliation Policy
- Payment Card Industry Data Security Standard (PCI DSS) Policy
- Prevention of Sexual Exploitation, Sexual Abuse, and Sexual Harassment
- Privacy Policy
- Professional Conduct, Non-Discrimination, and Non-Harassment Policy
- Prohibited Practices Policy
Purpose
Conservation International (CI) prohibits and actively works to prevent money laundering and terrorist financing in its operations. CI is committed to the highest ethical standards regarding anti-money laundering (AML) and countering the financing of terrorism (CFT). This AML/CFT Policy (the “Policy”) is designed to reduce the risk that CI will be used to launder money and to safeguard against the use of CI's funds for the financing of terrorism and other criminal activity.
Applying a risk-based approach, this Policy outlines the principles and minimum standards of internal AML/CFT controls to which CI will adhere to reduce legal and reputational risk. Additionally, this Policy outlines expectations and requirements for CI Staff and CI Delivery Partners to manage and reduce AML/CFT risk. This Policy further establishes principles and guidance regarding AML/CFT requirements and risks and to meet the following objectives:
- Prevent the misuse of CI funds for money laundering and the financing of terrorism;
- Comply with applicable AML/CFT legislation (including U.S. Patriot Act and Executive Order 13224) and AML/CFT donor-imposed obligations;
- Avoid and/or mitigate reputational risk;
- Support grantees in establishing or strengthening their capacities to address their own AML/CFT risks;
- Protect against establishing any relations or undertaking any transaction that may relate to or facilitate money laundering or terrorist financing;
- Exercise risk-based due diligence on funding recipients and donors; and Engage in continued review of this Policy and implement procedures as new threats and international standards evolve to prevent and detect money laundering and the financing of terrorism.
Scope
This Policy applies to all CI employees, interns, volunteers, and representatives (jointly, "CI Staff"), as well as CI grantees/awardees, contractors, suppliers, consultants, and their employees, sub-grantees/-awardees, and representatives (jointly, "CI Delivery Partners").
Implementation
AML/CFT Program Procedures and Due Diligence
CI adopts a risk-based approach to its due diligence of donors, CI Staff, and CI Delivery Partners to detect and address its risk related to money laundering and terrorism financing. CI's procedures and mitigation measures are commensurate with the risks identified, enabling decisions on how to allocate its resources in the most effective way. Under this approach, CI's AML/CFT program includes the following:
Systematic Sanctions
Screenings As a U.S.-based 501(c)(3), CI must demonstrate that all funds are used for charitable purposes and that funds are not used to support sanctioned entities or individuals. To meet those requirements, CI conducts AML/CFT-related risk assessments, verifies the identity of Delivery Partners and CI Staff, and screens against several sanctions lists, including those maintained by the U.S. government, the European Union, and the United Nations, which contain the names determined by such entities to be subject to financial or economic sanctions, administrative action, or other AML/CFT measures.
Details of CI's screening systems, screening documentation, record retention, and decision escalation procedures are addressed separately in the CI Security Screening Procedure.
AML/CFT Capacity Assessments
CI grantee risk assessments entail AML/CFT capacity assessments. To the extent that a capacity gap is identified and commensurate with the risk level assigned to the CI grantee, CI will provide guidance on necessary due diligence and screening procedures to build risk-adequate AML/CFT capacity and training on detecting and preventing AML/CFT risk. Written guidance for grantees on screening procedures is available here.
Donor Due Diligence
CI applies a risk-based approach to its due diligence of donors. As a general principle, CI will endeavor to have a reasonable belief that it knows the true identity of its donors, and based on established risk matrix, will verify and document the accuracy of the information received about them.
Records Retention
CI shall ensure mandatory minimum requirements for records retention for AML/CFT purposes, including to demonstrate that due diligence has been undertaken to prevent CI from being used for money laundering and/or terrorist financing and to ensure that sufficient information or documentation may be provided when requested by governing authorities.
Reporting and Mitigation
If anyone knows, suspects, or has reasonable grounds for thinking or suspecting (that a Delivery Partner or other person connected to CI is or has engaged in money laundering or terrorist financing, he/she must immediately report such matters to the General Counsel & Chief Compliance Officer, or Director of Risk Management directly or through Ethics Hotline, CI's established integrity grievance mechanism.
The Director of Risk Management will evaluate the information received and, in consultation with the General Counsel/Chief Compliance Officer, will determine necessary next steps, which may include terminating the relationship, rejecting, blocking, or reversing any transactions, and/or reporting the matter to the applicable governmental agencies, enforcement authorities, or donor organizations.
The Risk Management Director will retain records of such disclosure in accordance with CI's Record Retention Policy.
Training
CI shall ensure that CI Staff receive adequate AML/CFT training aimed at strengthening their knowledge and awareness of: (a) the relevant obligations, requirements, rules, and procedures set out in this Policy and accompanying procedures and guidelines, as well as any possible consequences for compliance failures; and (b) information and methods useful for identifying, and procedures for reporting, money laundering, terrorist financing, red flags, and other related risks.
Consequences of policy violations
Violation of this Policy by CI Staff will result in disciplinary or other action, including termination.
Violation of this Policy or failure to comply with the applicable contractual language by CI Delivery Partners will result in remedial action, including termination of the contract, award, sub-contract, or sub-award for cause with immediate effect.
Definitions
- Money Laundering: Money Laundering is defined as conversion or transfer of property, knowing that such property is the proceeds of crime.
- Terrorist Financing: Terrorist Financing includes providing in-kind, financial support or technical assistance for the purpose of, or in the knowledge that they are to be used to carry out terrorist acts.