Karwan-e-Hayat, Institute for Mental Health Care (KeH) is committed to full compliance with all applicable laws and regulations as stated in Pakistan’s Anti-Money Laundering Act 2010 (the Act). KeH has adopted and will enforce the provisions in Anti-Money Rules & Regulations to prevent and detect money laundering, terrorist financing, and other illegal activities.
This Policy Statement is designed to assist clients in adhering to KeH’s policy and procedures, which, if followed diligently, are designed to protect themselves, KeH, its Employees, its facilities, and its activities from money laundering or other illegal activities.
To ensure that KeH’s policies and procedures are adhered to, KeH will designate the Chief Officer as the Money Laundering Reporting Officer (MLRO) to coordinate the AML policies and practices of KeH. The MLRO is responsible for establishing and conducting Employee training programs to ensure that all appropriate Employees are aware of the applicable Anti – Money Laundering Laws and Regulations, KeH’s Anti-Money Laundering Policies & Procedures, and their responsibilities with respect to these policies.

• Comply with all Anti – Money Laundering Rules & Regulations of the jurisdictions it operates.
• Require relevant Employees to prevent, detect and report to the MLRO all potential instances in which KeH or its Employees, its facilities, or its activities have been or are about to be used for money laundering, terrorist financing, and other illegal activity.
• Require relevant Employees to attend anti-money laundering training sessions, so that all such Employees are aware of their responsibilities under KeH’s policies and procedures; this Compliance Manual; and as affected by current developments with respect to anti-money laundering events.

To accomplish these objectives, the following actions shall be taken;

• Identities of all new and existing donors will be verified to a reasonable level of certainty;
• A risk-based approach will be taken to the monitoring of donor’s tax and accounting affairs;
• Any suspicious activity will be reported to the MLRO, and all AML activities recorded;

Money laundering involves the placement of illegally obtained money into legitimate financial systems so that monetary proceeds derived from criminal activity are transformed into funds with an apparently legal source.

Money laundering has many destructive consequences both for society as a whole and for those entities involved in money laundering activities. With respect to society as a whole, money laundering may provide resources for drug dealers, terrorists, and other criminals to operate and expand their criminal activities.

With respect to entities, any involvement, whether it be to instigate, assist, conceal, or ignore the source, nature, location, ownership, or control of money laundering activities, can lead to both civil and criminal proceedings against both the individual and the entity involved.

Any Employee shall immediately notify the MLRO if he/she suspects or has any reason to suspect that any potentially suspicious activity has occurred or will occur if a transaction is completed.

Employees are encouraged to seek the assistance of the MLRO with any questions or concerns they may have with respect to the KeH’s Anti-Money Laundering Policies or Procedures.

Responsibilities of the MLRO include the following;

• Coordination and monitoring of KeH’s day-to-day compliance with applicable Anti- Money Laundering Laws and Regulations and KeH’s own Anti-Money Laundering Policy and Procedures;
• Conducting Employee training programs for appropriate personnel related to the KeH’s anti-money laundering policy and procedures and maintaining records evidencing such training;
• Receiving and reviewing any reports of suspicious activity from Employees;
• Determining whether any suspicious activity as reported by an Employee warrants reporting to senior management;
• Coordination of enhanced due diligence procedures regarding Clients; and Responding to both internal and external inquiries regarding KeH’s anti-money laundering policies and procedures.
• Monitor any developments in the Act and the requirements of the Act and shall update the policy accordingly.

• A Suspicious Activity Report (SAR) will be made to the relevant authority as soon as knowledge or suspicion arises of any criminal offense.
• The CFO will be responsible for deciding whether or not the suspicion of illegal activity is great enough to justify the submission of a SAR.
• Records of all identified suspicious activities and actions taken to respond suspicious activities shall be kept for a period of 10 years.

As part of KeH’s anti-money laundering program, relevant Employees are expected to be fully aware of KeH’s anti-money laundering policies and procedures. All relevant employees are required to read and comply with this Compliance Manual and address concerns to the MLRO that he/she has read, and understands KeH’s anti-money laundering policies and procedures.

Relevant employees are required;

• At a time specified by the MLRO, to undertake training programs on anti-money laundering policies and procedures;
• To get trained in how to recognize and deal with transactions that may be related to money laundering;
• To timely escalate and report the matter to the MLRO;
• To get themselves acquainted with Anti Money Laundering Rules & Regulations;
• To comply with the requirements of Rules & Regulations.

KeH has established a Know-Your-Donor / Patients policy to ensure that the identities of all new and existing donors are verified to a reasonable level of certainty.

The following documentation shall be requested from donors/patients at the time of establishing business relationships;

• Name
• Address (residential or business street address for an individual and registered address of an organization).
• Date of Birth
• Government-issued identification number, which will be a CNIC or National Taxpayer Number or passport number.

The organization will actively not accept high-risk donors that are identified as follows:

• Donors with businesses that handle large amounts of cash (i.e. involving Rs. 1000,000 or above) or complex unusually large transactions.
• Donors with complex business ownership structures with the potential to conceal underlying beneficiaries.
• Donors based in or conducting business in or through, a high-risk jurisdiction, or a jurisdiction with known higher levels of corruption, organized crime, or drug production/distribution.
• Situations where the source of funds cannot be easily verified.
• Unusual patterns of transactions that have no apparent economic or visible lawful purpose.
• Money sent to or received from areas known to have high levels of criminality or terrorist activity.

KeH business will conduct ongoing monitoring of business relationships with donors, to ensure that the documents, dates, or information held evidencing the donor’s identity are kept up to date.

The following are examples of changes in a donor’s situation that may be considered suspicious:

• A sudden increase in donations from an existing donor;
• Uncharacteristic transactions which are not in keeping with the donor’s known activities;
• Peaks of activity at particular locations or at particular times;
• Unfamiliar or untypical types of donors or donations.

Whenever there is cause for suspicion, the donor will be asked to identify and verify the source or destination of the transactions.

KeH’s money laundering risk assessments will be updated on a regular basis whenever material changes occur or any new program or service is initiated.