Sanctions and Terrorist Financing Policy

Al-Waris Foundation is committed to ensuring that its funds, assets, projects, grants and other resources are not knowingly made available to prohibited persons or organisations or used for terrorist purposes.

The charity will take proportionate steps to:

The charity recognises that humanitarian and charitable work may take place in higher-risk environments.

Risk must therefore be managed carefully without imposing unnecessary barriers that prevent legitimate charitable assistance.

This policy establishes the framework used by Al-Waris Foundation to manage risks relating to:

This policy applies to:

It applies to activity undertaken:

The Board of Trustees retains ultimate responsibility for ensuring that appropriate financial crime and sanctions controls exist.

Trustees should ensure that:

Operational screening and checks may be delegated.

Al-Waris Foundation will apply controls proportionately.

The level of due diligence should reflect factors including:

Not every low-risk UK purchase requires formal sanctions screening.

Higher-risk international transfers may require enhanced checks.

Financial sanctions may prohibit or restrict:

Al-Waris Foundation will comply with applicable UK sanctions law.

A designated person may be:

subject to applicable sanctions restrictions.

Where the charity identifies a credible potential match involving a relevant transaction, funds must not simply be transferred while the concern remains unresolved.

Where screening is appropriate, Al-Waris Foundation should use current official UK sanctions information or an appropriate screening service based on official data.

Searches should consider relevant identifying information such as:

A name match alone does not necessarily establish that a person is designated.

Potential matches require appropriate verification.

Screening may identify people who share a name with a designated person.

The charity should distinguish between:

Relevant evidence should be documented for significant decisions.

Terrorist financing involves providing, collecting, moving or making resources available for terrorist purposes or prohibited organisations.

Al-Waris Foundation must not knowingly allow charitable funds or assets to be:

The charity must not knowingly provide support to organisations proscribed under applicable UK law.

A delivery partner or recipient should not be assumed legitimate merely because it describes itself as:

Appropriate due diligence should be undertaken according to risk.

Al-Waris Foundation recognises that humanitarian work may be required in areas affected by:

The existence of these risks does not automatically prohibit lawful humanitarian activity.

The charity should instead:

A location may warrant enhanced scrutiny where there are factors such as:

Country risk should not be used as a substitute for evaluating the actual recipient and transaction.

Where Al-Waris Foundation supports charitable activity in Pakistan, Palestine or any other location within its charitable purposes, due diligence should reflect the actual risk environment at the relevant time.

The charity should consider:

The charity must not assume that all activity within a country or territory carries the same level of risk.

Before transferring material funds, the charity should establish proportionate information about the intended recipient.

This may include:

For organisations, due diligence may include reviewing:

Higher-risk grants may require stronger checks.

Individual beneficiaries should not routinely be subject to excessive sanctions screening where the activity and risk do not reasonably require it.

However, where:

additional checks may be appropriate.

Beneficiary dignity and data protection must be respected.

Material contractors may require sanctions and integrity checks where:

Contractor due diligence should be coordinated with the Overseas Operations and Partner Due Diligence Policy.

Before significant payments, the charity should verify that bank details reasonably correspond to the intended recipient.

Unexpected requests to:

should be investigated.

Payments to a personal account on behalf of an organisation should normally be avoided.

Where such an arrangement is genuinely necessary, the charity should document:

Where reasonably available, the charity should use reputable regulated financial institutions or payment providers.

The charity should not assume that a bank's compliance controls remove its own responsibilities.

In some overseas environments, conventional banking may not be reasonably available.

Where an informal or alternative transfer system is considered, the charity should assess:

The charity should maintain an audit trail sufficient to demonstrate the intended recipient and end use.

Cash carries increased diversion and traceability risks.

Cash transfers should be limited where safer alternatives are reasonably available.

Where cash is necessary, enhanced controls may include:

Grant-making must comply with this policy where relevant.

Higher-risk grants may require:

See the Grant Making Policy.

Procurement involving higher-risk locations or suppliers may require sanctions checks.

A supplier must not be selected merely because:

Procurement decisions must also consider due diligence and integrity.

Before a material partnership begins, Al-Waris Foundation should consider:

Partners should be required to notify Al-Waris Foundation of significant changes affecting the risk profile.

Where a partner or contractor proposes to subcontract significant work, Al-Waris Foundation should consider whether:

Material delivery chains should not become opaque.

The charity should maintain proportionate evidence that resources reached their intended charitable purpose.

Monitoring may include:

Monitoring should be stronger where risk is higher.

For physical water projects, records may include:

This assists in demonstrating end use of charitable funds.

Where funds support aid distributions, records may include:

Beneficiary personal data should not be collected unnecessarily simply to prove end use.

Restricted funds remain subject to sanctions and terrorist-financing controls.

A donor restriction does not require the charity to make a payment that would be unlawful.

Where lawful delivery becomes impossible, the trustees should obtain appropriate advice regarding alternative use or handling of the restricted funds.

Al-Waris Foundation does not need to investigate every ordinary donor.

Enhanced donor due diligence may be appropriate where:

Anonymous donations are not automatically prohibited.

However, unusually large anonymous or unexplained donations may warrant additional scrutiny.

The charity should consider:

The charity should not accept conditions requiring it to:

Where necessary, a donation may be declined or returned subject to appropriate legal and financial advice.

Screening should be proportionate.

It may occur:

There is no requirement to repeatedly screen every low-risk individual without justification.

Where formal screening is undertaken, the charity should maintain proportionate records of:

Sensitive information should be protected.

Where a potential sanctions match is identified:

Where the charity reasonably believes a relevant person or entity is subject to applicable sanctions restrictions, it must not knowingly proceed with a prohibited transaction.

The charity should obtain appropriate advice and follow applicable reporting requirements.

Where the charity holds funds or economic resources that may be subject to an asset freeze, the matter must be escalated immediately.

No person should:

such assets contrary to applicable law.

Professional or regulatory guidance should be sought promptly.

Where applicable, financial sanctions matters may require reporting to the Office of Financial Sanctions Implementation or another competent UK authority.

The charity should use current official reporting procedures rather than relying on outdated contact details embedded in this policy.

Where the charity identifies credible information concerning terrorist financing or related criminal conduct, appropriate reporting obligations should be considered promptly.

Professional legal advice should be obtained where necessary.

Where relevant, Al-Waris Foundation may need to notify:

One report does not necessarily remove another reporting obligation.

Significant concerns involving:

may require serious incident reporting.

See the Serious Incident Reporting Policy.

Warning signs may include:

A warning sign is not proof of wrongdoing.

It should trigger proportionate review.

Where a matter has been referred to a competent authority or professional adviser, people involved should avoid inappropriate disclosure that could:

Legal advice should be followed where applicable.

A conflict of interest may increase sanctions or diversion risk.

Relevant relationships involving:

must be declared.

See the Conflict of Interest Policy.

Sanctions and terrorist-financing concerns may overlap with:

See the Anti-Fraud, Bribery and Corruption Policy.

Due diligence and screening data must be handled in accordance with:

The charity should collect only information reasonably necessary for legitimate due diligence.

Sanctions enquiries may involve sensitive information.

Access should be limited to people who genuinely require it.

Potential matches should not be publicly described as confirmed sanctions subjects unless that has been established.

Material partner agreements may require obligations concerning:

Where relevant, grant agreements may provide that recipients must:

Higher-risk contractor agreements may require:

Al-Waris Foundation may suspend a payment where there is a credible unresolved concern relating to:

Suspension is a risk-control measure and does not necessarily establish wrongdoing.

A relationship may be terminated where:

The charity should consider safeguarding and beneficiary consequences when planning termination.

Where funds have been misused or diverted, reasonable recovery action should be considered.

The charity should consider:

In a genuine humanitarian emergency, the charity may need to act quickly.

Urgency may justify streamlined procedures but does not justify knowingly unlawful payments.

The charity should complete deferred checks as soon as reasonably practicable and maintain an appropriate decision record.

Higher-risk activity should be supported by a proportionate documented assessment.

The assessment may consider:

Significant sanctions or terrorist-financing risks should be reflected in the charity's Risk Register where appropriate.

The Board should receive proportionate information about material unresolved risks.

Relevant trustees and operational personnel should receive proportionate guidance concerning:

People handling higher-risk overseas transactions should receive more detailed guidance than people with no such responsibility.

Relevant records may include:

Records should be retained in accordance with the Records Retention and Disposal Policy.

No trustee, volunteer or representative may deliberately conceal a credible significant sanctions or terrorist-financing concern merely to:

Where there is uncertainty regarding:

appropriate professional or official guidance should be obtained before proceeding.

A breach may result in:

Action should be proportionate to the circumstances.

This policy should be read alongside:

This policy will be reviewed:

Version: 2.0 Status: Approved Approved by: Board of Trustees Approval date: 25/08/2026 Next scheduled review: 24/08/2027