Anti-money laundering and counter-terrorism financing (“AML/CTF”) policy

Policy Summary

Save Ethiopia is committed to conducting its business in accordance with all applicable Australian and other jurisdictions’ laws and regulations, and in a way that enhances its reputation in the charity or not-for-profit sector.

This policy records Save Ethiopia’s approach to the identification, mitigation and management of the risk that Save Ethiopia’s activities might be involved in the facilitation of money laundering or the financing of terrorism.

Details of policy

 1. Description of money laundering and terrorism financing list of 2 items

 Save Ethiopia defines money laundering (“ML”) as activity which is designed to conceal or disguise the true origin of criminally derived proceeds in order to make them appear to have been sourced from legitimate sources.

 Terrorist Financing (“TF”) is considered to be the act of providing financial support to terrorism or terrorist organisations to enable them to carry out acts of terrorism. 

2. Objectives of Save Ethiopia’s AML/CTF policy

Save Ethiopia has established an AML/CTF policy which sets the core principles for the management of ML/TF risk. The policy is global in nature and outlines organisation-wide standards to meet regulatory and ethical obligations in the jurisdictions in which Save Ethiopia does business and to
whose laws it is a subject. This contributes to the stability, integrityand strength of the global not-for-profit or charity sector and protects Save Ethiopia from reputational damage and regulatory action. The Policy is subject to regular reviewto ensure it remains current with regulator expectations and industry standards

3. The core principles

Save Ethiopia has adopted the following core principles:
list of 7 items
 Save Ethiopia opposes the crimes of money laundering and terrorist financing and maintains a framework to identify and mitigate the risk that its products and services could be used for such purposes.
 Save Ethiopia reports any activity that it detects which is suspicious and may involve potential money laundering or terrorism financing to the applicable Australian regulator.
 Save Ethiopia will comply with the AML/CTF laws, rules and regulations of the countries that relate to AML/CTF where Save Ethiopia has permanent places of business through which Save Ethiopia provides services.

 Save Ethiopia will endeavour to provide its products and services only for legitimate purposes to customers whose identities and needs Save Ethiopia has been able to reasonably ascertain.
 Save Ethiopia will take reasonable steps to ensure that sufficient funding and resources are available for the implementation and performance of activities required by Save Ethiopia’s AML/CTF Program.
 Save Ethiopia’s employees are required to attend AML/CTF training to understand their obligations under the relevant Australian laws, rules and regulations.
 Save Ethiopia will monitor its customers, their transactions, and its employees, consistent with the level of money laundering and terrorist financing risk they represent.
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Save Ethiopia will manage new and revised changes to Save Ethiopia’s activities,  business processes and systems to ensure that money laundering and terrorist financing risks are identified and managed.

4. Know your partner (“KYP”)
Save Ethiopia endeavours to follow all KYC policies and procedures relevant to the regions in which it operates. Applicable KYP policies and procedures to establish and verify the identity and bona fides of its officers and office holders as well as partners and their office holders will also be complied with.
These will include:
list of 8 items
 Officer and partner onboardingprocedures that identify types of officers, activities and transactions likely to pose a higher than average risk to Save Ethiopia and require a higher level of due diligence;
 Procedures to establish if partners are known or suspected money launderers, terrorists or otherwise engaged in criminal activity (e.g. reviewing customers against government/United Nations/regulators’ lists of proscribed persons);
 Enhanced Due Diligence undertaken where a transaction or a counterparty results in a heightened level of financial crime or reputational risk
 A risk-based periodic review of existing partners records to maintain currency and completeness;
 Ongoing monitoring of transactions conducted by partners using a risk based approach;
 Procedures prohibiting accounts/relationships, including payment processing, with shell banks;
 A clear statement on what records must be kept on officer and partner identification and individual transactions and their retention period; and
 Regular compliance reviews and independent audits of AML/CTF program and procedure documents and execution against established standards.
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5. Suspicious activity
Save Ethiopia staff are trained and made aware of “red flags”, or anything that is unusual or out of the ordinary when dealing with partners and officers
related information. Save Ethiopia has the relevant procedures and processes in place to ensure that any genuinely suspicious matters are detected and escalated for review by senior management.

6. Save Ethiopia’s AML/CTF training program
Save Ethiopia has a robust AML/CTF Training Program to educate employees in implementing and maintaining Save Ethiopia’s AML/CTF Program. All employees undergo initial AML/CTF training when they join Save Ethiopia. In addition, there are ongoing training requirements for all employees.

7. Save Ethiopia’s record retention
Save Ethiopia’s Record Management Policy requires retention of records for as long as required by applicable Australian and other jurisdiction laws, rules and regulations.

8. Independent review of the AML/CTF program
Save Ethiopia’s AML/CTF Program is subject to independent review in accordance with the requirements of each local jurisdiction. The results of the review are presented to senior management for review and action. In addition, regular reporting is provided by Compliance to Save Ethiopia’s Board.