Financial Sanctions, Anti-Terrorism and Anti Money Laundering Policy



financial sanctions, Anti-tERRORISM and anti money laundering pOLICY

Policy Statement


This policy sets out Sagoal’s commitment to a zero-tolerance approach to terrorism.

Sagoal renounces all forms of terrorism and will never knowingly support, tolerate or encourage terrorism or the activities of those who embrace terrorism and will make every effort to ensure that its resources are not used to facilitate terrorist activity.


Who must follow this policy

Sagoal board members, staff, consultants, contractors and volunteers, partners, beneficiaries and supporters must follow this policy.


why this policy is needed

Legal, regulatory and donor requirements.



All employee of Sagoal will be given an appropriate briefing to ensure that they are fully aware of this Policy. 


The Programme Manager and the Sagoal board Chairperson have the overall responsibility to monitor and verifying that any funds from Sagoal is not being used for terrorist activities.


The Programme Manager will ensure that any changes are clearly communicated to staff and volunteers.



First Draft


Approved by

Sagoal Executive Committee


Approval date

July 2019


Scheduled Review date

June 2022

1.    Key words and definitions

Financial sanctions: Financial sanctions are imposed by the United Nations, European Union, United Kingdom, United States, and other countries. They take different forms including:

  • asset freezes which restrict access to funds and economic resources

  • restrictions on various financial markets and activities in certain countries

  • directions to cease business of a specified type

  • directions to cease all business with certain sanctioned individuals or organisations.

Money Laundering: is the process of making illegally-gained proceeds (i.e., “dirty money”) appear legal (i.e., “clean”).

Charities can be targets for money laundering, if criminals believe they can put money into the charity and get it back out again.  This could be through refunds, loan repayments, or payments to an organisation or people the criminal controls.

Terrorism: an action that endangers or causes serious violence to a person/people; causes serious damage to property; or seriously interferes or disrupts an electronic system. The use or threat must be designed to influence the government or an international governmental organisation or to intimidate the public and is made for the purpose of advancing a political, religious, racial or ideological cause.

2.    Sagoal’s commitment

  1. The organisation will confirm the identity, credentials and good standing of the people or organisations it supports ensure that these people or organisations have no any association with terrorism.

  2. None of its funds or properties is made available to parties that are subject to financial sanctions or are otherwise proscribed by the United Nations or World Bank, or by the governments of the United Kingdom, European Union, or United States.

  3. The organisation will not donate any funds to known or suspected terrorist organisations or individuals.

  4. The organisation will report any known or suspected terrorist links to the relevant national authority.

  5. The organisation will provide training its staff so that they have an awareness of the risks related to terrorist activity, money laundering, and breaching sanctions.

  6. The organisation will ensure that its staff understands their obligations to report any actual or suspected terrorist activity or money laundering.

3.    Responsibilities

  1. The Sagoal Board and staffs are committed to avoid dealing with individuals and organisations associated with terrorism.

4.    Processes

  1. In the course of working with any partners Sagoal will ensure that the partner has no any association with terrorism.

  2. In the process of staff selection the selected candidates must be submitted the character verification letter from the local police prior to the formal appointment in any posts at Sagoal.

5.    Procedures

All staff, consultants and volunteers shall immediately report any belief or suspicion that Sagoal funds or property have been used by any sanctioned or proscribed party or by any party for the purposes of terrorism.

Reports should normally be made to the individual’s line manager, but may also be reported using Sagoal whistleblowing procedure. The report will then be assessed and responded.

6.    Revision

The Sagoal Executive Committee will review this policy to reflect new legal and regulatory developments and ensure good practice.


Approved by

Sagoal EC

July 2016

Next Review

Sagoal EC

June 2022

Authorised signature and stamp

Sagoal EC Chairperson