Purpose
Laraware Welfare Foundation ("LWF") is committed to preventing its funds, assets, and operations from being used for money laundering, terrorist financing, or any other illegal activity. This Anti-Money Laundering (AML) Policy sets out the controls and procedures we follow to detect, prevent, and report suspicious activity.
This policy is framed in compliance with the Prevention of Money Laundering Act, 2002 (PMLA), the rules made thereunder, FCRA guidelines, and the Financial Action Task Force (FATF) recommendations applicable to non-profit organisations.
Scope
This policy applies to all trustees, directors, employees, volunteers, and any third party acting on behalf of LWF. It covers all financial transactions, donations (domestic and foreign), grants, and expenditures handled by the Foundation.
Know Your Donor (KYD)
LWF conducts basic due diligence on all significant donors:
- Individual donors above ₹50,000: PAN card copy required for 80G receipts; identity verified against payment details.
- Corporate / institutional donors: Certificate of Incorporation or registration document, PAN, and authorisation letter required.
- Anonymous donations: Not accepted above ₹2,000 in a single transaction.
- Foreign donations: Accepted only through designated FCRA account and in compliance with FCRA, 2010 and MHA guidelines.
Prohibited Donations
LWF will not accept donations from:
- Individuals or entities on sanctions lists (UN, OFAC, or Indian government)
- Anonymous sources above the threshold stated above
- Sources where there is reasonable suspicion of illegal origin
- Shell companies or entities with opaque ownership structures
- Political parties or individuals acting on their behalf
Record Keeping
All financial records, donor details, and transaction documents are maintained for a minimum of 7 years as required under the PMLA and Income-tax Act, 1961. Records include:
- Donor KYD documents
- Receipts and payment confirmations
- Bank statements and account books
- Board resolutions approving large expenditures
Suspicious Transaction Reporting
Any employee, volunteer, or trustee who suspects a transaction may involve money laundering or terrorist financing must immediately report it to the Grievance Officer / Compliance Officer. LWF will file a Suspicious Transaction Report (STR) with the Financial Intelligence Unit – India (FIU-IND) as required by the PMLA.
No person shall tip off a donor or third party that a report has been or will be made.
Training
All staff and volunteers handling finances will receive AML awareness training during induction and refresher training annually.
Compliance Officer
Name: Rahul Tiwari
Role: AML Compliance Officer
Email: compliance@larawarefoundation.com
Phone: +91-9936622020
Violations
Any breach of this policy will result in disciplinary action, including termination of employment or volunteer engagement, and may be reported to law enforcement authorities where required by law.
Review
This policy is reviewed annually by the Board of Directors and updated to reflect changes in applicable laws and regulations.