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 does not provide funds, goods, services or employment to any person or entity on a sanctions or debarment list, and screens everyone before the first payment. Owner: Board Treasurer.
Lists checked
- United Nations Security Council Consolidated List
- EU consolidated list of financial sanctions
- US OFAC Specially Designated Nationals list and the US System for Award Management (SAM) exclusions, when US funds are involved
- UK sanctions list, when UK funds are involved
- World Bank and regional development bank debarment lists
- Any list named in a funding agreement
Who is screened and when
| Party | When | By |
|---|---|---|
| Staff, consultants, interns | Before contract and every year | Safeguarding and People Lead |
| Suppliers and contractors | Before purchase order; re-screened every 12 months | Finance and Compliance |
| Sub-grantees and partners, including their key staff | Before agreement and at each renewal | Ethics and Compliance Officer |
| Donors (income) | Before agreement | Ethics and Compliance Officer |
| Programme participants receiving cash or goods | Only where a donor requires it or the setting is high-risk | Project manager with Compliance |
A possible match
- Stop the transaction at once.
- Record the check and send it to the Ethics and Compliance Officer the same day.
- The Officer verifies (date of birth, address, registration number) within two working days.
- A confirmed match is refused and reported to the donor within the timeline in Policy 15.
Records and partner clauses
Every check is saved with date, list and result for six years. All partner and supplier contracts include a clause requiring them to apply equivalent screening and to notify ASF of any match.