Anti Money Laundering (AML) Rules for Fundraisers
1. Purpose
To prevent Globalgood Corporation (“Globalgood”) and its fundraisers from being used to launder illicit funds or finance terrorism, this policy sets out mandatory Anti‑Money Laundering (AML) procedures. It distils statutory obligations under the U.S. Bank Secrecy Act (BSA), the USA PATRIOT Act, the EU Anti‑Money Laundering Directives (AMLD 4–6), the U.K. Money Laundering Regulations 2017, and Financial Action Task Force (FATF) Recommendations.
2. Scope
This policy applies to:
- Existing Fundraisers—employees, volunteers, contractors, and partner organizations authorized to solicit or process donations.
- Prospective Fundraisers seeking such authorization.
- All cash, cheque, wire, credit‑card, ACH, and in‑kind contributions, regardless of donor domicile.
3. Threshold for Enhanced Due Diligence (EDD)
Gifts of USD 10,000 or greater—or the equivalent in euros or other currencies—trigger Enhanced Due Diligence, including Source‑of‑Funds (SoF) declaration and Politically Exposed Person (PEP) screening.
Currency conversions must use the daily U.S.‑Federal‑Reserve reference rate (or ECB rate for EUR) on the gift date.
4. Legal & Regulatory Framework
Region | Key Laws / Guidance | Core Obligations for Charitable Entities |
United States | Bank Secrecy Act (31 U.S.C. 5311–5332); 31 CFR Part 1010; FinCEN Advisory FIN‑2023‑AML | KYC, CTR for cash ≥ $10k, SAR, recordkeeping 5 yrs |
European Union | EU AMLD 5 & 6; EBA Guidelines | Beneficial‑ownership registers, risk‑based CDD, sanctions screening |
United Kingdom | Money Laundering Regulations 2017; JMLSG Guidance | Customer Due Diligence, PEP checks, suspicious activity reporting |
Canada | Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA); FINTRAC Guidance | Large‑cash transaction reporting ≥ CAD 10k, STR, ID verification |
Australia | AML/CTF Act 2006; AUSTRAC Rules | KYC, reporting threshold AUD 10k, ongoing monitoring |
5. Customer Due Diligence (CDD) Procedures
5.1 Standard CDD (All Donations)
- Collect donor details: full name, address, email, phone.
- Screen against Globalgood’s global sanctions list (OFAC, EU, UN, HM Treasury, DFAT).
- Retain ID evidence if donor total annual contributions exceed USD 2,000.
5.2 Enhanced Due Diligence (EDD)
Triggered when:
- Donation ≥ USD 10,000 (or EU equivalent).
- Donor flagged as PEP or related to a high‑risk jurisdiction.
EDD steps:
- Source‑of‑Funds Declaration (SoF) – donor completes and signs the Form GG‑AML‑SoF‑01, detailing income source, business activities, and funding chain.
- PEP Screening – run donor through a reputable database (e.g., Dow Jones Risk & Compliance).
- Beneficial Ownership Verification – if donation is via corporate or trust entity, identify and screen 25 % + beneficial owners.
- Compliance Approval – Chief Compliance Officer (CCO) signs off before receipting.
- Ongoing Monitoring – flag donor for continuous monitoring for 12 months.
6. Politically Exposed Persons (PEPs)
- Domestic PEP: current or former senior U.S. officials (federal, state, municipal) and their immediate family.
- Foreign PEP: current or former officials of foreign governments.
- International‑Org PEP: senior executives of international bodies (UN, World Bank, IMF, AU, etc.).
Donations from PEPs require CCO approval regardless of amount.
7. Sanctions & Watchlist Screening
All donors (and beneficial owners) must be screened before receipting funds. Matches require immediate escalation to the Compliance Office and suspension of the transaction until cleared.
8. Acceptable Payment Channels
Channel | Maximum per Single Transaction | Notes |
Cash | USD 9,999 | > USD 10k prohibited; direct donor to banking channel |
Bank wire / ACH | No limit (EDD > USD 10k) | Must originate from donor‑named account |
Credit / debit card | USD 25,000 | Subject to card network monitoring |
Check | No limit | Hold funds until clearance |
Cryptocurrency | Not accepted (see Cryptocurrency Directive 2024‑01) | — |
9. Record‑Keeping & Reporting
- Retention: AML records, SoF forms, screening logs—7 years minimum.
- Currency Transaction Reports (CTR): U.S. cash gifts ≥ USD 10k must be reported to FinCEN within 15 days.
- Suspicious Activity Reports (SAR/STR): file within 30 days of suspicion event.
- Audit Trail: maintain unique AML case number linking all documents.
10. Training & Certification
- All fundraisers must complete an AML e‑learning module within 30 days of onboarding and annually thereafter.
- Passing score: 80 %. Non‑compliance suspends fundraising privileges.
11. Roles & Responsibilities
Role | AML Responsibilities |
Fundraisers | Collect donor info; perform initial screening; escalate EDD cases |
Compliance Analysts | Conduct PEP/sanctions checks; review SoF forms; maintain logs |
Chief Compliance Officer (CCO) | Final approval for EDD / PEP donations; file regulatory reports; liaise with regulators |
Finance Department | Validate payment channels; reconcile AML flags with ledger |
12. Non‑Compliance Consequences
- Internal disciplinary action (up to termination)
- Revocation of fundraising authority
- External penalties: fines, imprisonment, revocation of tax‑exempt status
13. Review & Amendment
Reviewed annually or upon legislative change. Updates approved by the CCO and published under Legal Policies and Notices on globalgoodcorp.org.
14. Contact Information
Globalgood Compliance Office
Email: compliance@globalgoodcorp.org
Phone: +1 614‑829‑5030
Mail: 7211 Charleton Ct., Canal Winchester, OH 43110, USA
Disclaimer
This policy is for informational purposes only and does not constitute legal advice. Fundraisers and donors should consult qualified professionals for guidance on specific transactions.