Please see below charity guidance from the Bailiwick of Guernsey Financial Intelligence Unit.
The managing officers of all charities/NPOs are required to assess and be aware of the charities/NPOs risk exposure and, as necessary, introduce mitigating measures to address the risk of a registered charity/NPO being used for criminal purposes. This means money laundering, fraud, bribery and corruption. For charities/NPOs that carry out international activity (other than remitting funds to a UK -registered charity/NPO), this also means terrorist financing. This is in recognition of the higher risk profile arising from international activity and is the subject of separate guidance.
Risk mitigation measures:
- Put in place controls* to ensure that it and its activities cannot be used for the purposes of money laundering, fraud, bribery and corruption.
- Identify donors and beneficiaries in certain situations.
- Periodically review compliance with the legislation and take steps to address any issues of non-compliance.
This risk-based approach means that requirements do not apply when an event is unlikely. For example, a charity/NPO with a purely domestic focus is unlikely to receive payments from outside the Bailiwick so will not be required to carry out identification measures on donors.
Controls may include all or some of the following, depending on the circumstances of the charity/NPO;
- Segregation of duties where possible
- Regular bank reconciliation checks
- Multiple signatories for all bank account activity
- Having professionally audited accounts
- Restricting full access to all areas of the accounting system
- Regular review of and spot checks on payroll records to ensure consistency with staff movements
- Reconciliation of supplier statements, invoices and creditor balances
- Documented authority thresholds for the approval of and payments to suppliers
- Random checks to ensure expenditure below key thresholds is legitimate
- Procedures to address any employee/trustee connections with suppliers