Anti-Money Laundering & Sanctions Policy

Policies

Arcangelo Anti-Money Laundering & Sanctions Policy

This version approved by the Board on 23 February 2026. This Policy will be reviewed at least every 12 months, or sooner if required by changes in law or guidance.

Purpose

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 with applicable law and regulation on the prevention of money laundering, breach of sanctions, and terrorism.

Background

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.

Engagements in High-Risk Third Countries

Any proposed engagement or activity by Arcangelo in a high-risk third country as identified from time to time by the UK Financial Action Task Force, 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. See also:

https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2ory Notice: October 2025 - GOV.UK

Acceptance of large gifts

Acceptance of all gifts exceeding the amount of £5,000 from donors who are not current trustees of Arcangelo will be subject to:

  • Receipt by Arcangelo of proof of the donor’s identity in the form of: 
    • in the case of natural persons not personally known to the trustees or senior management, 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):

A written record of the search results and proof of identity will be retained by Arcangelo in accordance with its Privacy Policy.   

The above checks shall not be required to be repeated where a donor has previously given a gift exceeding £5,000 and there has been no change in their circumstances to warrant additional due diligence.

Arcangelo may additionally in its discretion carry out the above checks for gifts under the value of £5,000 where it considers there are unusual or suspicious circumstances which warrant additional due diligence.  

Venues, Agents and Promoters

The charity will be mindful of the potential risk of facilitating money laundering when engaging with venues, agents or promoters that are not typically active in the field of classical music performances and unknown to the management and trustees and reserves the right to require confirmation and checks of the sort applicable to large gifts as referred to above.  Examples may include where unfamiliar counterparties are based outside of the UK (in particular if based in or linked to a country included on the ‘grey list’ or ‘black list’ of the Financial Action Task Force) or where unusual circumstances arise regarding payment (e.g. funds received from a different source to the contracting party). See also:

 https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html

In the first instance, the Executive Director will report any proposals of concern to the board of trustees with a view to consultation and decision as to how best to proceed. See also:

Donees

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:

  1. More detailed checks will be conducted to ascertain if a “name match” is in fact an “identity match”
  2. Arcangelo will not disclose to the relevant counterparty that there has been a match (although Arcangelo may request additional information from the counterparty to confirm/clarify that the match is not a “false positive”);
  3. The board of trustees of the charity will be notified with a view to consultation and decision as to how best to proceed
  4. If the board so determines, advice from charities counsel will be sought
  5. 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
  6. The charity will make all required reports to relevant authorities in respect of the matter.

Questions

For questions about this policy, contact the Executive Director of Arcangelo, Julian Forbes, at julian@arcangelo.org.uk