This Anti-Money Laundering and Counter-Terrorist Financing Policy (hereinafter – the Policy) was developed as a practical tool for public and charitable organizations (hereinafter – POs/COs) registered in Ukraine. Its purpose is to strengthen internal safeguards against the risks of involvement in money laundering, terrorist financing, and related financial crimes.
The relevance of introducing such instruments is conditioned both by the ongoing armed aggression of the Russian Federation against Ukraine and the resulting increase in financial and security risks, as well as by Ukraine’s international obligations in the field of anti-money laundering and counter-terrorist financing (AML/CFT). International standards — in particular Recommendation 8 of the Financial Action Task Force (FATF) – explicitly recognize the important role of self-regulation, internal controls, and best practices within the non-profit sector.
The existence and effective implementation of such practices should be taken into account by public authorities and obliged entities when assessing an organization’s risk profile. The Policy is not intended to introduce a mandatory or unified standard for all civil society and charitable organizations. Instead, it offers a flexible, risk-based tool that can be adapted to the scale, resources, and nature of activities of a particular organization.
The Policy combines both recommended approaches and ready-to-use template solutions for implementation at the level of internal organizational policies and procedures. It is designed as a “building-block” framework for establishing an internal system to prevent the risks of involvement in money laundering, terrorist financing, and related financial crimes.
Read the Policy at the link.
This publication was funded by the European Union. Its contents are the sole responsibility of the Centre for Democracy and Rule of Law (CEDEM) and do not necessarily reflect the views of the European Union.
The “CSO Meter: Empowered for Action” project is implemented by the European Center for Not-for-Profit Law Stichting (ECNL) and its partners: Transparency International Anticorruption Center in Armenia; Promo-LEX Association in Moldova; and ISAR Ednannia in Ukraine.
