Policy 6 — Anti-Money Laundering and Counter-Terrorist Financing

Earlier policy library. This page belongs to an earlier library of ASF policies. The current, approved governance set is the ASF Standards Package 2026 (GOV, OPS, QMS and EV documents). Where this page and the 2026 package differ, the 2026 package applies.

ASF Institutional Policy Manual · Aligned with PHIG, September 2026

Part of the ASF policy framework, aligned with the equivalent PHIG policy. To raise a concern: see the ASF Complaints and Reporting Channel.

ASF will not let its accounts, grants or partners be used to hide the origin of criminal money or to finance terrorism. Owner: Board Treasurer.

Legal framework: the French Monetary and Financial Code (Code monétaire et financier) provisions on the prevention of Money Laundering and Terrorism Financing, EU anti-money-laundering rules and the requirements of each donor. Suspicious activity is reported to Tracfin (the French financial intelligence unit) through ASF’s bank where the law requires.

Controls

Know your donor and partner: identity, beneficial ownership and sanctions checks before any agreement (Policies 4 and 7).
Banking only: all income and payments over 500 EUR go through ASF’s registered bank accounts. Cash is limited to a petty-cash float of 1,000 EUR, reconciled monthly.
No third-party payments: ASF pays only the entity that supplied the goods or services, into an account in that entity’s name.
Refunds: returned only to the original payer and account.
Records: kept for at least six years after the end of the project or longer if a donor requires.

Warning signs

A donor or partner reluctant to reveal ownership or source of funds.
Offers to overpay and ask for a refund, or to pay through a third party or another country.
Requests to route funds through ASF for an unrelated purpose.
Transactions with no clear programme purpose or with high-risk jurisdictions.

Reporting

Any suspicion goes to the Ethics and Compliance Officer the same day. Do not warn the person involved (“tipping off”). The Officer decides, with the the Board Chair, whether to report to the bank and authorities and to donors (Policy 15).