ANTI MONEY LAUNDERING & COUNTER TERRORISM POLICY

The Anti Money Laundering & Counter Terrorism Policy, effective June 2024, establishes the framework for FSD Africa to prevent and combat money laundering (ML) and terrorism financing (TF). The policy mandates strict screening of third parties, risk assessments prior to programme implementation, and a formal reporting structure led by a designated Money Laundering Reporting Officer (MLRO) to ensure compliance with international standards and national laws in Kenya and donor countries.

• FSD Africa commits to complying with specific regulatory frameworks to combat terrorism financing and money laundering, including the UK Counter-Terrorism Legislations, 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, as well as those designated as such by Kenya, donor countries, or subscribed international bodies.
• FSD Africa has appointed the Risk and Compliance Lead as the Money Laundering Reporting Officer (MLRO), who is responsible for monitoring policy compliance, training staff, making external reports to regulators, and developing a risk mitigation plan for Board approval.
• The policy mandates a rigorous screening process for all third parties, including suppliers, grantees, and potential staff, against sanctioned lists from the UN, the Kenya Government, and donor country governments. FSD Africa will not accept funding or proceed with investments without identifying beneficial owners.
• Risk assessments for money laundering and terrorism financing must be conducted before the adoption and implementation of FSD Africa programmes, with mitigation controls monitored on a quarterly basis.
• Personnel are required to report suspicions of ML and TF immediately to the MLRO, Director Corporate Services, or CEO. Tipping off involved parties is strictly prohibited as it constitutes a breach of the Kenya POCAMLA and a disciplinary matter.
• Grantees receiving funding from FSD Africa must adopt similar anti-ML and TF procedures, ensure staff training, and report any suspicions of money laundering, terrorism financing, or sanctions breaches to FSD Africa within 48 hours.

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} }