Anti Money Laundering

Anti–Money Laundering and Counter–Terrorist Financing Policy

1. Purpose

The purpose of this policy is to protect Forward Africa Education Trust from being used for money laundering or terrorist financing, and to ensure that all funds are used only for legitimate charitable purposes. We are committed to complying with all UK relevant laws (including charity laws) and to maintaining transparency and accountability in all our financial dealings.

2. Scope

This policy applies to all trustees, staff, volunteers, and anyone acting on behalf of the charity. It covers all activities involving the transfer or use of money, whether in the UK or overseas.

3. What is Money Laundering?

Money laundering is the process of taking profits from crime and corruption and transforming them into legitimate assets. It takes criminally-derived ‘dirty funds’ and converts them into other assets so they can be reintroduced into legitimate commerce. This process conceals the true origin or ownership of the funds, and so ‘cleans’ them. Terrorist financing means using, or intending to use, funds to support terrorism — even if the funds came from legal sources.

4. Our Commitments

• We will take reasonable steps to know who we are dealing with before giving or receiving money.
• We will only work with reputable partners who share our values and are properly registered and accountable.
• We will keep clear financial records of all income and expenditure, especially funds sent abroad.
• We will report any suspicious or unusual activity to the Charity Commission and, where appropriate, the National Crime Agency (NCA).

5. Due Diligence Procedures

Before working with any overseas partner or project, the trustees will:

  1. Obtain the partner’s registration details and governing document (if applicable).
  2. Require all partners to sign a partnership agreement.
  3. Check that the partner has a real presence and can show how funds will be spent.
  4. Record the partner’s bank details and verify they are held in the organisation’s name.
  5. Ask for brief reports or receipts for how funds are used.

Trustees will record these checks and review them annually.

6. Record Keeping

• All financial transactions will be supported by receipts, invoices, or bank records.
• Records will be kept for at least six years.
• Transfers to Africa will include notes showing purpose, amount, recipient, and approval by trustees.

7. Identifying and Reporting Suspicious Activity

Any trustee, volunteer, or partner who suspects that funds may be misused must:
1. Report it immediately to the Chair of Trustees.
2. The Chair will assess the concern and, if appropriate, report it to the Charity Commission or NCA using official channels.
All concerns will be handled confidentially and without prejudice.

8. Training and Awareness

Trustees and key volunteers will be briefed on this policy at least once a year. New trustees will be introduced to the policy when they join the charity.

9. Review

This policy will be reviewed annually or sooner if there are significant changes in our activities or legal requirements.