Arcangelo Anti-Money Laundering & Sanctions Policy
Last reviewed March 2023
The purpose of this policy is to document the procedures that will be followed by Arcangelo (Arcangelo, or the charity) in order to facilitate compliance by it with applicable law and regulation on the prevention of money laundering, breach of sanctions, and terrorism.
The board of trustees of Arcangelo, after consideration of the nature and location of the charity’s activities, the nature of its counterparties and other relevant matters, has concluded that charity’s exposure to the risks of money-laundering, breach of sanctions, and terrorism are low. The board of trustees has nevertheless deemed it in the best interests of the charity to implement the procedures set out in this policy as measures reasonably designed to minimise any such risks.
High Risk Engagements
Any proposed engagement or activity by Arcangelo in a high-risk jurisdiction, as defined by the United Kingdom from time to time, shall be presented in advance for approval by the full board of trustees of the charity. It is expected that any such engagement or activity ordinarily would be approved only in exceptional circumstances after taking professional advice, under which compliance with applicable law can be assured.
Acceptance of gifts
Acceptance of all large donations exceeding the amount of [£1,000] will be subject to
- proof of the donor’s identity in the form of
- in the case of natural persons, receipt of copies of passport and proof of address or
- in the case of legal entities, satisfactory confirmation of identity relevant to the form of the entity, such as records appearing in Companies House, and
- the donor’s name being run through, and not generating any hits, in any of the following databases (or any successor databases that the relevant authorities may publish from time to time):
- the Home Office List of Proscribed Organisations (https://www.gov.uk/government/publications/proscribed-terror-groups-or-organisations–2;
- The Office of Financial Sanctions Implementation’s consolidated list of Asset Freeze Targets: https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets and
- The Office of Financial Sanctions Implementation’s consolidated list entities subject to capital market restrictions: https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of- targets/ukraine-list-of-persons-subject-to-restrictive-measures-in-view-of-russias-actions- destabilising-the-situation-in-Ukraine
Venues, Agents and Promoters
As a measure reasonably designed to prevent breach of applicable AML and sanctions rules, before entering into any engagement with a venue, agent or promoter with which the charity has not previously engaged, the charity will require confirmations and checks of the short applicable to large donors pursuant to clause 4 above.
Arcangelo does not currently make donations to others. If it should do so in future, the board will determine such additional measures to be followed as may be required to facilitate compliance with applicable law and guidance.
Procedures in the Event of a “Match”
If in the conduct of the checks contemplated by this policy it is found that the name of the relevant counterparty returns a “match” from one of the official databases, the following procedures will be followed:
- More detailed checks will be conducted to ascertain if a “name match” is in fact an “identity match”
- The board of trustees of the charity will be notified with a view to consultation and decision as to how best to proceed
- If the board so determines, advice from charities counsel will be sought
- In any event, approval of the board of trustees will be required before the charity enters into a relationship or accepts a donation from the person triggering an identity match, and
- The charity will make all required reports to relevant authorities in respect of the matter.
For questions about this policy, contact firstname.lastname@example.org