Hitaishee Foundation (“we,” “our,” or “us”) is committed to maintaining the highest standards of integrity and compliance with all applicable laws and regulations, including the Prevention of Money Laundering Act, 2002 (PMLA), and the Foreign Contribution Regulation Act (FCRA). This Anti-Money Laundering (AML) Policy outlines our procedures to prevent, detect, and report money laundering activities.

1. Purpose

The purpose of this AML Policy is to:

• Prevent the use of Hitaishee Foundation’s resources and activities for money laundering, terrorism financing, or other illegal activities.
• Ensure compliance with all applicable legal and regulatory requirements related to AML.
• Protect the integrity and reputation of Hitaishee Foundation.

2. Scope

This policy applies to all employees, volunteers, board members, and third-party partners of Hitaishee Foundation. It covers all donations, grants, transactions, and other financial activities conducted by or on behalf of the organization.

3. Legal and Regulatory Compliance

• Prevention of Money Laundering Act (PMLA), 2002: We comply with the PMLA and any related rules and regulations issued by the Government of India. We ensure that our financial activities do not facilitate money laundering or the financing of terrorism.
• Foreign Contribution Regulation Act (FCRA), 2010: As an organization receiving foreign contributions, we strictly adhere to the FCRA requirements, ensuring that all foreign donations are used for their intended purposes and properly reported to the relevant authorities.

4. Know Your Donor (KYD) Procedures

To mitigate the risk of money laundering, Hitaishee Foundation implements Know Your Donor (KYD) procedures:

• Identification and Verification: We require donors, especially those contributing large sums or from high-risk jurisdictions, to provide identification documents. This includes verifying the identity of individuals and entities making donations to the foundation.
• Due Diligence: We conduct due diligence on all donors and beneficiaries to ensure they are not involved in any illegal activities. Enhanced due diligence is conducted for high-risk donors, including those from countries identified by the Financial Action Task Force (FATF) as having strategic deficiencies in AML measures.

5. Monitoring and Reporting

• Transaction Monitoring: We regularly monitor transactions to detect any unusual or suspicious activities. This includes reviewing donation patterns, amounts, and sources for consistency and legitimacy.
• Suspicious Activity Reporting: If we identify any suspicious transactions or activities, we are committed to reporting them to the appropriate authorities in compliance with the PMLA. Suspicious activity reports (SARs) will be filed without notifying the parties involved.

6. Record Keeping

We maintain accurate and complete records of all donations, transactions, and KYD documentation for at least five years. These records are securely stored and made available for inspection by regulatory authorities as required.

7. Training and Awareness

• Employee Training: We provide regular training to our employees, volunteers, and board members on AML laws, regulations, and best practices. This training helps ensure that everyone associated with Hitaishee Foundation understands their responsibilities in preventing money laundering.
• Awareness Programs: We also engage our partners and donors in awareness programs to highlight the importance of AML compliance and ethical financial practices.

8. Governance and Oversight

• AML Compliance Officer: We have designated an AML Compliance Officer responsible for overseeing the implementation of this policy, conducting due diligence, monitoring transactions, and ensuring compliance with all AML laws and regulations.
• Board Oversight: Our Board of Directors provides oversight to ensure that the organization adheres to this policy and meets its legal and ethical obligations.

9. Review and Updates

This AML Policy is reviewed regularly and updated as necessary to reflect changes in laws, regulations, and best practices. Any updates will be approved by the Board of Directors and communicated to all relevant stakeholders.

10. Reporting Violations

If you suspect any violation of this AML Policy or encounter any suspicious activity, please report it immediately to our AML Compliance Officer or through our confidential reporting channels. We are committed to investigating all reports thoroughly and taking appropriate action.

Contact Information

For any questions or concerns regarding this AML Policy, please contact:

Hitaishee Foundation
Email: Hitaisheefoundation@gmail.com
Phone: +91-9811018100, 01144791810
Address: Hitaishee Foundation 108, old no 98-A g/f Bharat nagar New delhi-110025