Table of Contents
1. Introduction
2. Objectives
3. Scope
4. Legal and Regulatory Framework
5. Definitions
6. Responsibilities
7. Customer Due Diligence (CDD)
8. Risk Assessment
9. Reporting Obligations
10. Record Keeping
11. Training and Awareness
12. Monitoring and Review
1. Introduction
The Anti-Money Laundering (AML) Policy of the Society for Urban & Rural Enlightenment (SURE) is designed to prevent and detect money laundering activities and ensure compliance with applicable laws and regulations in India. SURE is committed to upholding the highest standards of integrity and accountability.
2. Objectives
- Prevent the organization from being used for money laundering activities.
- Ensure compliance with legal and regulatory requirements related to anti-money laundering.
- Establish procedures for identifying, assessing, and mitigating money laundering risks.
- Foster a culture of compliance and ethical conduct within the organization.
3. Scope
This policy applies to all employees, volunteers, contractors, and board members of SURE. It covers all activities and transactions conducted by the organization.
4. Legal and Regulatory Framework
This policy is aligned with the provisions of the Prevention of Money Laundering Act, 2002 (PMLA), and other relevant laws and regulations in India. SURE will also adhere to guidelines issued by regulatory authorities such as the Financial Intelligence Unit - India (FIU-IND).
5. Definitions
- Money Laundering: The process of making illegally-gained proceeds appear legal.
- Customer Due Diligence (CDD): The process of verifying the identity of customers and assessing their risk profile.
- Suspicious Transaction: A transaction that raises concerns about possible involvement in illegal activities.
6. Responsibilities
- Board of Directors: Ensure overall compliance with AML policies and regulations.
- AML Compliance Officer: Appointed to oversee and implement the AML Policy, conduct risk assessments, and report suspicious activities.
- Employees and Volunteers: Follow AML procedures, report suspicious activities, and participate in training programs.
7. Customer Due Diligence (CDD)
- Identification: Verify the identity of customers before establishing a relationship or conducting transactions.
- Verification: Use reliable, independent sources to verify customer information.
- Enhanced Due Diligence: Apply additional scrutiny for high-risk customers and transactions.
- Ongoing Monitoring: Continuously monitor customer transactions to detect unusual or suspicious activities.
8. Risk Assessment
- Risk Identification: Identify potential money laundering risks related to customers, transactions, and products.
- Risk Assessment: Assess the identified risks based on their likelihood and potential impact.
- Risk Mitigation: Implement measures to mitigate identified risks, such as enhanced due diligence and transaction monitoring.
9. Reporting Obligations
- Internal Reporting: Employees must report any suspicious activities to the AML Compliance Officer.
- External Reporting: The AML Compliance Officer must report suspicious transactions to the Financial Intelligence Unit - India (FIU-IND) as required by law.
- Confidentiality: Ensure that reports are kept confidential and that the identity of reporting individuals is protected.
10. Record Keeping
- Documentation: Maintain records of customer identification, transaction details, and risk assessments.
- Retention Period: Retain records for at least five years from the date of the transaction or the end of the customer relationship, whichever is longer.
- Accessibility: Ensure records are readily accessible for review by regulatory authorities.
11. Training and Awareness
- Training Programs: Provide regular training on AML policies, procedures, and regulations to all employees and volunteers.
- Awareness Campaigns: Conduct awareness campaigns to promote a culture of compliance and vigilance against money laundering.
12. Monitoring and Review
- Monitoring: Regularly monitor compliance with the AML Policy and procedures.
- Review: Conduct periodic reviews and updates of the AML Policy to reflect changes in laws, regulations, and organizational activities.
- Audits: Perform internal and external audits to ensure the effectiveness of the AML program.