TAHMO has a zero policy on money laundering or any illegal financial activities, and we are committed to being open and accountable. The anti-money laundering policy is applied to all employees including the CEO, Director, contractors, and subcontractors who are directly or indirectly working for TAHMO. We do not support money laundering or funding of terrorist or criminal activities. To avoid financial crimes, we follow all finance management principles to avoid financial risks and ensure compliance with all laws and regulations; both domestic and international laws to avoid money laundering.

The definition of money laundering[1] “is the illegal process of making large amounts of money generated by criminal activities, such as drug trafficking or terrorist funding, appear to have come from legitimate sources”

TAHMO will ensure an open discussion and expect all its employees and contractors to share a concern about any possible breach of the code of conduct and expects all its employees, CEO, directors, contractors, and third parties working for TAHMO not to engage in any form of money laundering nor any financial criminal activities.

TAHMO does a risk assessment of all relative operations including grants and donations and makes all inquiries/due diligence before accepting donations. We have put together all processes and procedures to mitigate any risk that may occur.

TAHMO conducts due diligence on third parties for identification and verifications like collecting all necessary information and conducting continuous monitoring where needed.

TAHMO has internal controls and monitoring, and procedures to prevent money laundering including transaction reporting and monitoring mechanisms.

Funded project procedures

• TAHMO will communicate all project budgets that will need to be implemented in the project activities to the funders.
• Be open and declare the purpose of funding to donors and the public and ensure the funding is used according to the initial plans.
• Documentation and proof of how the funds have been used in the project including receipts and transactions will be made available to funding agencies.

Reporting

Any suspicious money laundering activities should be reported for investigation via complaints@tahmo.org.

TAHMO will appoint Anti-Money Laundering Reporting Officer (AMLRO), who is in charge and responsible for financial compliance and reporting any suspicious money laundering in the organization.

If any TAHMO employee is suspected to engage in money laundering activities, it’s the duty of AMLRO to report this as soon as possible. If the AMLRO is involved in such activities use the complaint email as reporting mechanism.

All suspicion should be accompanied by a provision of detailed evidence and supporting documentation such as transactions, amounts, reasons for transactions, third parties information, and a reason for suspicion filled with a form and sent via email to the authorities for further investigation and action.

Any employee who reports suspicious activities will be protected from retaliation; the reporting complaint email is one of the channels to be used when reporting.

Consequences of not complying with this policy

Violation of the anti-money laundering may cause several civil penalties including a sentence to jail time. TAHMO employees, contractors, or subcontractors who violate this policy may face several civil and criminal penalties including termination of the contract.

Policy implementation

The implantation of AML policy should be communicated to all TAHMO staff, contractors, subcontractors, interns, and other stakeholders to ensure its understanding and adherence throughout the organization. Training and awareness of money laundering risk on AML policy will be provided to all staff to increase their understanding.

TAHMO will do regular reviews and auditing to ensure an effective  Anti-Money Laundering policy and remain current and effective.

[1] Investopedia