Grants Anti-Money Laundering (AML) Policy

1. Introduction

1.1. Purpose: The purpose of this Anti-Money Laundering (AML) Policy is to outline Grants’ commitment to preventing money laundering, terrorist financing, and other illicit activities. This policy establishes a framework to detect, prevent, and report suspicious activities and ensure compliance with applicable laws and regulations.

1.2. Scope: This policy applies to all employees, contractors, agents, and any other individuals or entities acting on behalf of Grants. It encompasses all activities, services, products, and relationships of Grants that may pose a risk of money laundering or terrorist financing.

2. Legal and Regulatory Framework

2.1. Compliance with Applicable Laws Grants is committed to complying with all applicable national and international laws, regulations, and standards concerning AML and countering the financing of terrorism (CFT). This includes but is not limited to the Palestinian Anti-Money Laundering Law, regulations issued by the relevant authorities, and international conventions or recommendations related to AML/CFT.

3. AML Program

3.1. Designation of AML Officer: Grants shall appoint an AML Officer responsible for overseeing the implementation and maintenance of the AML program. The AML Officer will serve as the point of contact for all AML-related matters and ensure compliance with relevant laws and regulations.

3.2. Risk Assessment: Grants shall conduct a comprehensive risk assessment to identify, assess, and understand the potential money laundering and terrorist financing risks associated with its activities, products, and services. The risk assessment shall be periodically reviewed and updated to reflect changes in Grants’ risk profile.

3.3. Customer Due Diligence (CDD) a. Customer Identification: Grants shall establish procedures to identify and verify the identity of customers, beneficial owners, and authorized representatives in accordance with applicable regulations. This includes obtaining and maintaining accurate records of identification documents and other relevant information. b. Enhanced Due Diligence: Enhanced due diligence measures shall be applied to high-risk customers, business relationships, and transactions, as determined by the risk assessment.

3.4. Reporting of Suspicious Activities: Grants shall implement procedures for the identification, reporting, and investigation of suspicious activities, including transactions that may be linked to money laundering, terrorism financing, or other illicit activities. Any suspicions or red flags shall be promptly reported to the designated authority.

3.5. Record Keeping: Grants shall maintain records of customer identification, transactional activities, and any other relevant information in accordance with applicable laws and regulations. These records should be kept secure, readily accessible, and retained for the required retention period.

3.6. Training and Awareness: Regular training programs shall be conducted to ensure that all relevant employees and individuals are aware of their AML obligations, understand the risks associated with money laundering and terrorist financing, and are familiar with Grants’ AML policies, procedures, and reporting mechanisms.

3.7. Monitoring and Audit: Ongoing monitoring and periodic internal audits shall be conducted to assess the effectiveness of Grants’ AML program, identify any deficiencies, and implement necessary corrective measures.

4. Reporting and Cooperation

4.1. Reporting to Authorities: Grants shall promptly report any suspicious activities or transactions, as required by law, to the appropriate authorities or regulatory bodies.