AML Policy
PURPOSE
readease.net intends to prevent the direct or indirect use of its funds to launder the proceeds of crime through readease.net. The suggestion that readease.net is in any way connected to money laundering can damage our reputation and undermine the company’s credibility with its partners and clients.
The purpose of this policy is to prevent sanctions violations and the use of readease.net as a money-laundering vehicle.
SCOPE OF APPLICATION
The policy applies to all readease.net employees and authors. In addition, all implementing partners and vendors are subject to anti-money laundering policies.
readease.net works with local partner organizations, most of which we have a long history of working with and know about their reliability. We believe that operating this way, there is a relatively low risk that our funds will inadvertently fall into the hands of those who will use them for violent purposes. However, given the consequences of any proven or suspected money laundering, readease.net has taken many steps in the process of selecting partner organizations and vendors to mitigate this risk further.
DISSEMINATION
The Anti-Money Laundering Policy is openly available on readease.net. All updates will be shared directly with readease.net employees, partners, and customers. Critical checks in the policy are part of the initial process descriptions that are part of the onboarding program for all new employees.
The anti-money laundering policy is referenced in all legal agreements with partner organizations and vendors.
DEFINITION
Money laundering is the process whereby the profits of crime are funneled through financial systems in an attempt to hide their illicit origin and returned to the launderer indirectly.
PREVENTION
readease.net takes the following steps to reduce the risk of accidental and intentional use of funding for money laundering:
Due Diligence on Partners, Authors, and Customers: readease.net has an affiliate alliance policy that prescribes restrictions on the type of organizations we partner with. An affiliate risk assessment is conducted for all new affiliates and clients, indicating the various risks of collaboration. Based on the evaluation, steps are taken to mitigate the risks identified. To make sure that readease.net does not enter into financial relationships with criminal organizations, new partners, writers, and customers are subject to some type of verification. Additional research will be conducted if the verification process reveals potential money laundering risks. Only if the other research provides assurance can cooperation be considered.
Audit Committee: The readease.net Audit Committee helps fulfill its responsibilities by independently reviewing our internal controls’ financial reporting and effectiveness. The Committee monitors the effectiveness of the external and internal audit functions and meets its responsibility to determine the nature and extent of the risks it is willing to take to achieve its strategic goals.
Procedures: readease.net has a Quality Management System with procedures for support functions in finance and administration that all offices must follow in the country/cluster.
Segregation of Duties: Obligations in crucial financial processes are divided among several employees rather than assigned solely to one employee. System workflow signatures and/or approvals are required to avoid unauthorized transactions at various stages of any financial transaction process.
“Three Lines of Defense” – System of Internal Control: readease.net has a system of internal control that follows the “three lines of defense” type of approach. The first line is policies, processes, and procedures for managing operations. The second line is the risk management processes, which focus on identifying risks and weaknesses. The third line is the internal audit function, which independently controls the first two lines.
Budget Management: Budget versus actual expenditure reports are prepared and reviewed monthly for each project and organizational unit. An extensive consolidated report is submitted to the Board of Supervisors every four months. All budgets are kept in the accounting system.
Proper Books and Records: readease.net supports a multi-currency accounting system that tracks revenue and expenses with a unique link to projects, funding sources, and external third parties in the system. All revenues and expenses are linked to coded funding sources, and all program expenses are related to specific projects and coded partners. In addition, readease.net keeps all supporting documentation (receipts, invoices, and supporting documents) as required by law.
Cash and Bank Management: Monitoring includes regular counts of cash and monthly bank reconciliations, levels of authorization for financial transactions, segregation of duties, and signatures/system approvals. In addition, all cheques necessitate two signatures, and all bank and wire transfers require two signatures as well.
