The Foundation does not accept the use of its name, relationships, programmes or resources for money laundering, terrorist financing, sanctions evasion or other unlawful activity. These standards apply to our engagement with contributors, sponsors, programme partners, suppliers and other counterparties.
A proportionate, risk-based approach
Due diligence must reflect the nature of the relationship, its geography, funding route, delivery arrangements and potential exposure to financial crime. Legitimate philanthropic activity must not be treated as inherently high risk. Higher-risk circumstances require more scrutiny and an appropriate approval route.
Know the counterparty and the purpose
Obtain and verify relevant identity, registration and authority information. Understand who owns or controls an entity, where relevant, why the relationship exists and how funds will be used. Seek source-of-funds information proportionate to risk and source-of-wealth evidence where enhanced scrutiny is warranted. Unexplained third-party payments, opaque structures or pressure to bypass checks must be escalated.
Enhanced scrutiny
Politically exposed persons, complex ownership, higher-risk jurisdictions, unusual payment patterns and material adverse information require a documented risk assessment. PEP status alone is not a finding of wrongdoing. Where the relationship requires enhanced controls, obtain appropriate authority, additional evidence and closer monitoring before proceeding.
Sanctions and prohibited dealings
Screen relevant parties against applicable sanctions and assess potential matches before commitments or payments. Confirmed restrictions must be handled in accordance with the applicable freezing, non-dealing, reporting and other legal requirements. A potential match is not automatically a confirmed designation; uncertainty must be referred promptly for competent assessment.
Monitor use and destination
Check that payments, delivery and programme expenditure remain consistent with the agreed purpose. Keep records of counterparties, approvals and material changes. Do not proceed where necessary information is missing, an unresolved prohibition applies or the proposed use is unlawful. Do not return or redirect suspected funds automatically where that could breach a freezing duty or prejudice lawful reporting.
Escalation and reporting
Suspected financial crime must be escalated promptly to an authorised, unconflicted responsible person. Preserve records and assess any reporting duty, including reporting to the Financial Intelligence Unit where applicable. Observe legal restrictions on disclosure and tipping off. A commercial decision to decline or end a relationship does not replace a statutory reporting obligation.
The relevant Mauritian framework includes the Financial Intelligence and Anti-Money Laundering Act 2002, applicable regulations and the United Nations sanctions legislation. The precise statutory obligations depend on the entity, activity and circumstances. This public statement does not claim that the Foundation is a regulated financial institution or that a particular compliance officer has been appointed.