ANTI MONEY LAUNDERING & COUNTER TERRORISM POLICY

The document outlines FSD Africa's commitment to combating money laundering and terrorism financing in accordance with international and national laws, including those of Kenya and its donor countries. It defines a risk-based approach involving screening, training, and monitoring, and assigns specific oversight roles to the Risk and Compliance Lead (as MLRO), the CEO, and the Board of Directors. The policy extends these compliance requirements to all personnel and grantees, mandating strict reporting timelines and due diligence processes.

• FSD Africa commits to complying with specific regulatory frameworks, including UK and Kenya Counter-Terrorism legislations and the Proceeds of Crime and Anti-Money Laundering Act 2009 (POCAMLA).
• The organization prohibits providing support or resources to any individual or entity involved in terrorism, weapons proliferation, human rights violations, or narcotics trafficking, or those designated as such by Kenya, donor countries, or subscribed bodies.
• FSD Africa employs a five-part approach to manage money laundering (ML) and terrorism financing (TF) risks: training and awareness, screening, risk assessments, monitoring, and responding and reporting.
• The Risk and Compliance Lead is designated as the Money Laundering Reporting Officer (MLRO), responsible for monitoring policy compliance, training staff, making external reports to regulators, and developing a risk mitigation plan for Board approval.
• Mandatory screening is required for all third parties, including suppliers, grantees, and potential staff, against sanctioned lists from the UN, the Kenya Government, and donor country governments.
• Grantees are required to adopt similar anti-money laundering and counter-terrorism financing procedures, train their own staff, and report any suspicions of breaches to FSD Africa within 48 hours.
• The Board of Directors holds ultimate accountability for the policy, delegating overall oversight of ML and TF risk management to the Finance Audit and Risk Committee (FARC).

APA

FSD Africa (2024). ANTI MONEY LAUNDERING & COUNTER TERRORISM POLICY. https://fsdafrica.org/wp-content/uploads/2025/05/Anti-Money-Laundering-and-Counter-Terrorism-Financing-Policy-1-1.pdf

Chicago

FSD Africa. ANTI MONEY LAUNDERING & COUNTER TERRORISM POLICY. 2024. https://fsdafrica.org/wp-content/uploads/2025/05/Anti-Money-Laundering-and-Counter-Terrorism-Financing-Policy-1-1.pdf.

Wikipedia

{{cite report |author=FSD Africa |title=ANTI MONEY LAUNDERING & COUNTER TERRORISM POLICY |date=June 2024 |url=https://fsdafrica.org/wp-content/uploads/2025/05/Anti-Money-Laundering-and-Counter-Terrorism-Financing-Policy-1-1.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{fsdafrica2024anti, author = {{FSD Africa}}, title = {{ANTI MONEY LAUNDERING \& COUNTER TERRORISM POLICY}}, institution = {FSD Africa}, year = {2024}, month = jun, url = {https://fsdafrica.org/wp-content/uploads/2025/05/Anti-Money-Laundering-and-Counter-Terrorism-Financing-Policy-1-1.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }