Anti-Money Laundering Policy

Policy Statement

The trustees of The Henry van Straubenzee Memorial Fund are committed to protecting our charitable funds against all types of fraudulent activity, including money laundering.
As a registered charity, we must comply with charity law. This includes ensuring that our assets are safeguarded and properly used to meet our charitable objectives. We also have a duty to protect the public funds we receive. Our resources must not be used to support criminal or terrorist purposes or in any way that breaches applicable sanctions.

This policy applies to all our operations in the UK and worldwide unless local legal requirements are more rigorous, or if applying the policy would be illegal under local laws.

Our Commitment

We will assess the risks of becoming involved with terrorism and money laundering, and of breaching applicable sanctions. We will put in place proportionate measures to manage those risks, while continuing to work in difficult and challenging places.

We are committed to:

  1. Having systems, procedures and controls in place to ensure that we manage the risk of becoming involved in financing or supporting terrorist activity, money laundering, or breaching sanctions for the highest risk transactions.
  2. Checking that those we fund or work with are not on any lists of proscribed terrorist groups or persons, financial sanctions lists or other regulatory compliance lists, and assessing the risks if we are training its staff so that they have an awareness of the risks related to terrorist activity, money laundering, and breaching sanctions.
  3. Ensuring all trustees, staff and volunteers show due diligence and are encouraged to report any attempted, suspected or actual illegal activity when processing donations or fundraising activity.
    If at any time unusual requests or transactions come to light, they will be reported to the Board of Trustees, who will use a risk-based measure to make the necessary assessments.
    If at any time any fundraising activity is recognised by the Board or Trustees as having the potential to be fraudulent, tax avoidance or part of suspected criminal proceeds, the matter will be reported to the relevant authorities including Action Fraud and The Charity Commission or HMRC.
  4. Ensuring that we meet our obligations to report to external authorities.
    We require all those receiving our funds to act in accordance with this policy to ensure that our funds and assets are not used to finance or support terrorist activity or to launder money.

We also use an external independent examiner who carries out a thorough annual review across all areas of the charity.  During this process, if any suspicious or potential money laundering activity comes to light, this would be reported to our Board of Trustees.

We will provide adequate and appropriate resources to implement this policy and will ensure it is communicated and understood.

We will review this global policy statement every two years to reflect new legal and regulatory developments and ensure good practice.

This review: 14 May 2021
Next Review: May 2023