Carrying out AML checks on charities can seem more complex than verifying an individual client. The guidance below provides an overview of the customer due diligence (CDD) steps typically required.
You should always refer to your agency's AML policy and seek further guidance from your Money Laundering Officer (MLO) or an independent compliance adviser if you are unsure how to proceed.
Charities are registered with the Charity Commission (for charities in England and Wales) or the Office of the Scottish Charity Regulator (OSCR) (for charities in Scotland). Many charities are also registered as limited companies, so you should also check Companies House where applicable.
When acting for a charity, you should:
- Confirm that the individual instructing you is authorised to act on behalf of the charity.
- Obtain the charity's registration details from the Charity Commission or OSCR, together with a Companies House Report where the charity is a registered company.
- Identify the charity's trustees and any other relevant officials.
- Assess the overall money laundering risk presented by the organisation.
- Carry out customer due diligence (CDD) on the Persons with Significant Control (PSCs) where the charity is a company, or on the trustees, using a risk-based approach in accordance with your agency's AML policy.
If a charity is registered with Companies House, you should follow the same process as onboarding and AML checking any other company.
If the charity does not have any shareholders with a 25% or greater stake or no Person with Significant Control (PSC), you should carry out AML checks on the trustees listed on the Charity Commission (England and Wales) or OSCR (Scotland) register.
If a charity is not registered with Companies House, you should onboard and AML check the trustees as individual clients, following the standard individual onboarding process.
You should always refer to your agency's AML policy and seek further guidance from your Money Laundering Officer (MLO) or an independent compliance adviser if you are unsure how to proceed.