Policies and Procedures


POLICY STATEMENT

Karwan-e-Hayat (KeH), a non-profit mental health organization, is committed to full compliance with the Anti-Money Laundering Act 2010 (the Act) of Pakistan. To combat money laundering, terrorist financing, and other unlawful activities, Karwan-e-Hayat has adopted and will enforce relevant anti-money laundering (AML) policies and regulations.

This policy serves as guidance for clients to adhere to KeH’s procedures, which are designed to protect the organization, its employees, facilities, and operations from being exploited for illegal purposes. KeH will assign the Chief Officers as the Money Laundering Reporting Officer (MLRO) to oversee the implementation of the AML policies. The MLRO will ensure compliance with these policies and lead employee training programs on anti-money laundering laws and obligations.

OBJECTIVE

  • Comply with all applicable anti-money laundering regulations.
  • Require staff to prevent, detect, and report any potential money laundering or suspicious activities to the MLRO.
  • Mandate participation in AML training sessions to ensure all employees are familiar with KeH’s AML policies and procedures, as well as the latest developments in anti-money laundering practices.

To meet these objectives, the following steps will be implemented:

  • Verify the identity of all new and current donors with a reasonable degree of assurance.
  • Monitor donor transactions using a risk-based approach.
  • Document all AML actions and report any suspicious activities to the MLRO.

UNDERSTANDING MONEY LAUNDERING

Money laundering involves disguising illegally obtained funds by introducing them into legitimate financial systems, making the illicit proceeds appear lawful. This practice can empower criminals such as terrorists, drug traffickers, and others to continue their unlawful activities.

For any organization, involvement in money laundering, whether by direct action or through negligence, can lead to severe legal consequences. Employees must report any suspicion of money laundering activity immediately to the MLRO. In case of any questions or concerns regarding KeH’s AML policies, employees are encouraged to contact the MLRO.

COMPLIANCE MONITORING AND MANAGEMENT

The MLRO will be responsible for:

  • Overseeing KeH’s compliance with AML laws and its internal AML policies.
  • Conducting employee training on AML procedures and maintaining training records.
  • Reviewing reports of suspicious activities and determining whether to escalate them to senior management.
  • Monitoring updates to the Anti-Money Laundering Act and adjusting KeH’s policies as required.
  • Managing enhanced due diligence procedures for donors and addressing public or internal queries regarding AML practices.

REPORTING SUSPICIOUS ACTIVITY AND RECORD KEEPING

A Suspicious Activity Report (SAR) must be filed with the relevant authority if criminal activity is suspected. The CFO will determine whether the suspicion warrants a SAR submission. All records related to suspicious activities and the corresponding actions will be retained for a period of 10 years.

EMPLOYEE TRAINING

All employees must familiarize themselves with KeH’s AML policies and procedures. The MLRO will organize training programs to educate employees on how to recognize and respond to potential money laundering transactions. Employees are also expected to report any suspicious activities promptly and stay updated on AML regulations.