Counter-Terrorism and Anti-Money Laundering Policy

1. Purpose of this Policy

This policy outlines Global Vascular Companionship’s commitment to complying with Australian and international laws pertaining to Anti-Money Laundering (AML) and counter-terrorism. It establishes processes and policies to mitigate the risk of money laundering, terrorism financing, or support for terrorists and terrorist organizations, particularly those identified on relevant watchlists.

2. Scope of the Policy

This policy applies to the following individuals and entities associated with Global Vascular Companionship:

• GVC staff members, contractors, and office volunteers
• GVC Board of Directors
• Partner organizations
• Vendors & suppliers
• Participants in GVC program activities

3. Definitions

Anti-Money Laundering (AML): Laws, regulations, and procedures aimed at preventing criminals from disguising illegally obtained funds as legitimate income.

Counter-terrorism: Activities designed to prevent acts of terrorism.

Prescribed Lists: Lists of suspected terrorists or supporters of terrorists.

Details of applicable lists are provided in Appendix A.

Appendix B
https://www.austrac.gov.au/sites/default/files/2019-06/npo-risk-assessment-FINAL-web.pdf

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4. Legislative Framework and Standards

​To fulfill its international obligations in alignment with United Nations Security Council Resolutions 1267 (and subsequent resolutions) and 1373, aimed at freezing the assets of terrorists, the Government has enacted legislation criminalizing the possession of assets owned or controlled by terrorist organizations or individuals, or facilitating their access to assets.

Partners, as defined, are individuals, groups, or organizations collaborating with Global Vascular Companionship to achieve mutually agreed development objectives.

Global Vascular Companionship also abides by section 5.3 of the Australian Criminal Code Act of 1995, which pertains to the management of funds and assets associated with suspected terrorist organizations.

The Department of Foreign Affairs and Trade (DFAT) maintains a Consolidated List of individuals and groups subject to asset freezing measures due to terrorism-related activities. This list is accessible on the DFAT website. Global Vascular Companionship acknowledges its responsibility to ensure it does not engage with any individuals or groups listed on the Consolidated List.

In addition to the Consolidated List, the Australian Government maintains a list of terrorist organizations proscribed under the Criminal Code. This List of Terrorist Organizations is accessible on the National Security Australia website. It is deemed unlawful to direct the activities of, recruit individuals for, provide or receive training from, transfer funds to or from, or provide support or resources to any organization listed as a terrorist entity on this website.

Global Vascular Companionship adheres to the guidelines outlined in the Attorney General’s Department’s document titled “Safeguarding your organization against terrorism financing: A guidance for non-profit organizations”. This ensures compliance with the DFAT Head Agreement, stipulating that contracts with “delivery partners” incorporate anti-terrorism requirements.

5. Policy Statement

​Global Vascular Companionship is dedicated to preventing the misuse of funds for terrorist activities. We assess potential partners to ensure they have no links to proscribed entities or individuals. We reference risk assessments provided by authoritative bodies to identify higher-risk financial implementing partners, screening their staff and vendors against prescribed lists where necessary.

We inform our partners of counter-terrorism risks and appropriate actions to mitigate them. GVC implements anti-money laundering principles, including ‘Know Your Customer’, to verify the identity of donors and beneficiaries and to prevent the laundering of illegal funds.

As Global Vascular Companionship, we prioritize the implementation of robust strategies to mitigate potential vulnerabilities and red flags across various stages of our operations. While acknowledging that many of these measures are anticipatory and may not yet be directly applicable to our current operational context, we are committed to proactively addressing any potential risks as we evolve and expand our activities. The phases below are based on https://www.austrac.gov.au/sites/default/files/2019-06/npo-risk-assessment-FINAL-web.pdf
Potential vulnerabilities, red flags and mitigation strategies table page 57/76. See Appendix B.

In the collection phase, we emphasize meticulous record-keeping to ensure transparency and accountability in documenting all donations received, even though we currently lack strategies for transferring funds overseas. Staff members undergo comprehensive training on due diligence to recognize and respond to any suspicious activities, laying the foundation for future practices. Regular independent audits will be a cornerstone of our approach to review and enhance our collection practices once we establish a strategy for overseas fund transfers.

Regarding storage practices, we prioritize secure storage within mainstream channels to safeguard funds, recognizing the importance of maintaining detailed records even in our current operational scope. While routine spot checks may not be immediately relevant, we are committed to implementing these measures as our operations evolve, ensuring the integrity of our storage procedures from the outset.

In the transfer stage, although we do not currently have strategies for overseas transfers, we underscore the importance of maintaining meticulous records of all transactions and transfers, including any potential future international transactions. Staff training on identifying and reporting suspicious activity remains a critical aspect of our preparations, laying the groundwork for future compliance with established protocols and practices.

For expenditure, our commitment to meticulous record-keeping and transparent financial practices remains unwavering, even as we navigate our current operational landscape. We recognize the value of routine spot checks and independent audits in verifying expenditure records and preventing potential misuse of funds, and we are committed to implementing these measures as we develop and expand our activities.

In program delivery, we prioritize effective oversight and due diligence, even in our current capacity. While we may not yet be engaged in offshore programs in any financial capacity or collaborations with third-party partners, we are laying the groundwork for future initiatives by emphasizing the importance of on-site representatives, thorough project planning, and regular monitoring and evaluation processes.

In summary, while many of these mitigation strategies are forward-looking and may not yet be directly applicable to our current operations, they reflect our proactive approach to risk management and our commitment to upholding the highest standards of integrity and accountability as we grow and expand our impact.

6. Policy in Practice

​This policy will be integrated into Global Vascular Companionship’s organizational culture and practices through the following measures:

a) Mentors and mentees are selected through stringent application process which includes an application form, interview, letters of recommendation from their hospital and their society.

b) Addressing anti-terrorism concerns with partners during the development of relevant Memorandums of Understanding (MoUs) and partner agreements.

c) Conducting regular checks on all relevant personnel, suppliers, and partners against proscribed terrorist lists. Any new personnel/supplier will be check against the terrorist list.

d) Monitoring and evaluating activities, including budget and acquittal processes, to ensure that funds are allocated and utilized solely for approved program activities.

e) Adhering to Know Your Customer principles to mitigate the risk of any potential money laundering incidents. GVC will approach Australian governmental organisations such as Dfat, medical industry and charities registered in Australia for Donations. All donations will be declared in the annual financial report.

f) Requiring any Global Vascular Companionship personnel, partner organizations, or external individuals who have reasonable suspicions of money laundering or terrorism financing to report such suspicions immediately to the CEO. Disclosures can be made following the processes and procedures outlined in Global Vascular Companionship’s Whistleblower Policy or Complaints Handling Policy.

g) The CEO, Treasurer and any executive involved in fundrasing are required to familiarise themselves with the following document appendix 2.
https://www.austrac.gov.au/sites/default/files/2019-06/npo-risk-assessment-FINAL-web.pdf

7. Monitoring and Review of Policy

This policy will be regularly monitored and reviewed to ensure its effectiveness and compliance with relevant laws and regulations. The Program Manager, in collaboration with the Finance Manager, is responsible for managing and maintaining this policy.

Appendix A:

Listed Terrorist Organisations

For an effective counter-terrorism regime, it is vital that our laws target not only terrorist acts, but also the organisations that plan, finance and carry out such acts. In 2002, a range of terrorist organisation offences were inserted into the Criminal Code Act 1995 (the Criminal Code). More information is available at Laws to combat terrorism.

Under the law, there are two ways for an organisation to be identified as a terrorist organisation:

•  The prosecution can prove beyond reasonable doubt that an organisation is a terrorist organisation as part of the prosecution for a terrorist offence.
•  The organisation may be specified in Regulations as a terrorist organisation. This process, known as ‘listing’, requires certain processes set out in the legislation to be followed.

Terrorist Organisations

The list of organisations currently listed as terrorist organisations under the Criminal Code is regularly updated by Australian National Security.

Appendix B:

https://www.austrac.gov.au/sites/default/files/2019-06/npo-risk-assessment-FINAL-web.pdf

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