Jamia tul Mastwaar

Policy Owner: Jamia tul Mastwaar
Policy Type: Anti-Money Laundering & Counter-Terrorist Financing
Effective Date: 10 September, 2025
Review Date: 20 September, 2026
Version: 1.0
Approved By: Managing Director

1. Introduction

Jamia tul Mastwaar is committed to maintaining the highest standards of integrity, transparency and accountability in the management and use of funds.

Jamia tul Mastwaar does not permit its funds, bank accounts, donation platforms, facilities or services to be used for money laundering, terrorist financing, fraud, corruption, tax evasion or any other unlawful activity.

This Anti-Money Laundering (AML) Policy establishes the principles and procedures that Jamia tul Mastwaar follows to identify, prevent, detect and report potential financial misconduct and unlawful use of its resources.

2. Purpose

The purpose of this policy is to:

Protect Jamia tul Mastwaar from being used for money laundering or terrorist financing.
Promote transparency and accountability in financial activities.
Establish appropriate controls for donations and other sources of income.
Identify and manage unusual or suspicious transactions.
Ensure funds are used only for legitimate and authorized purposes.
Establish responsibilities for employees, management, volunteers and relevant representatives.
Support compliance with applicable laws and regulatory requirements.
Protect donors, beneficiaries, staff and the organization from financial abuse.

3. Scope

This policy applies to:

Jamia tul Mastwaar management and governing bodies.
Employees and teachers.
Finance and administration staff.
Volunteers.
Fundraising personnel.
Authorized representatives.
Contractors and consultants involved in financial activities.
Individuals responsible for receiving, processing or approving donations.
Bank accounts, donation platforms and other financial channels operated or controlled by Jamia tul Mastwaar.

It applies to funds received through:

Donations.
Zakat.
Sadaqah.
Subscription programs.
Grants.
Sponsorships.
Fundraising campaigns.
Bank transfers.
Online payment systems.
Cheques.
Cash donations.
Other lawful sources of income.

4. Policy Statement

Jamia tul Mastwaar has zero tolerance for knowingly accepting, transferring, concealing or using funds derived from criminal or unlawful activities.

The organization will take reasonable and proportionate measures to:

Know and understand the sources of its funds.
Maintain appropriate financial records.
Identify unusual or suspicious transactions.
Conduct appropriate due diligence where necessary.
Maintain transparent financial controls.
Prevent unauthorized use of organizational funds.
Report suspected unlawful activity to the appropriate authority where required.

5. What is Money Laundering?

Money laundering is the process through which individuals or organizations attempt to conceal the criminal origin of money or assets and make them appear legitimate.

Money laundering may involve:

Receiving money generated through criminal activity.
Moving funds through different accounts or organizations.
Concealing the true owner or source of funds.
Using donations or charitable organizations to disguise unlawful funds.
Converting illegally obtained money into apparently legitimate assets.

Jamia tul Mastwaar will not knowingly participate in or facilitate any such activity.

6. Terrorist Financing

Terrorist financing involves providing, collecting, transferring or making funds or other financial resources available for the purpose of supporting terrorism or terrorist activities.

Jamia tul Mastwaar will not knowingly:

Provide funds to prohibited individuals or organizations.
Transfer funds for terrorist activities.
Facilitate fundraising for prohibited purposes.
Permit its name, accounts or platforms to be used to support terrorism.
Establish financial relationships intended to circumvent applicable sanctions or restrictions.

7. Legal and Regulatory Compliance

Jamia tul Mastwaar will comply with applicable Pakistani laws, regulations and regulatory requirements relating to money laundering, terrorist financing, financial transparency, charitable organizations and sanctions.

The organization will take account of relevant requirements issued by competent Pakistani authorities, including applicable requirements under the Anti-Money Laundering Act, 2010, as amended, and relevant rules, regulations, notifications and guidance.

Where Jamia tul Mastwaar operates or receives funds internationally, it will also consider applicable requirements in the relevant jurisdiction.

Because legal requirements can change, the organization should periodically review this policy and obtain professional legal or compliance advice where necessary.

8. Governance and Responsibility

The management of Jamia tul Mastwaar has overall responsibility for ensuring that appropriate AML controls are maintained.

Management should:

Approve and periodically review this policy.
Establish appropriate financial controls.
Ensure responsible persons are appointed for financial oversight.
Provide appropriate training.
Review significant financial risks.
Ensure concerns are investigated appropriately.
Take corrective action when weaknesses are identified.

9. AML Compliance Responsibility

Jamia tul Mastwaar should appoint an appropriate person to oversee AML and financial compliance.

AML/Compliance Officer:
Name: ______________________________
Designation: _________________________
Phone: ______________________________
Email: _______________________________

The responsible person should:

Monitor AML-related risks.
Review unusual transactions.
Maintain appropriate records.
Coordinate internal investigations.
Escalate significant concerns to management.
Make or coordinate reports to relevant authorities where required.
Maintain confidentiality of sensitive compliance information.
Review this policy periodically.

10. Donor Due Diligence

Jamia tul Mastwaar will apply proportionate due diligence to donors and funding sources based on the level of financial and reputational risk.

For ordinary low-value donations, routine records may be sufficient.

For larger, unusual or higher-risk donations, Jamia tul Mastwaar may request appropriate information such as:

Donor's name.
Contact information.
Identification information where legally appropriate.
Source or nature of the funds.
Purpose of the donation.
Relationship to the organization.
Relevant organizational or business information for institutional donors.

The level of due diligence may depend on the amount, source, nature and circumstances of the donation.

11. Anonymous Donations

Jamia tul Mastwaar recognizes that some donors may prefer privacy.

However, anonymous donations must not be accepted where doing so would create unacceptable legal, financial or safeguarding risks.

The organization may apply additional review to:

Large anonymous donations.
Unusual cash donations.
Donations involving unexplained third parties.
Donations accompanied by unusual conditions.
Donations that appear inconsistent with the organization's activities.

Where appropriate, the organization may decline or return a donation if its source cannot be reasonably established or if accepting it could create legal or regulatory concerns.

12. Source of Funds

Jamia tul Mastwaar should take reasonable measures to understand the source of significant or unusual funds.

Potential indicators requiring additional review may include:

A donation significantly larger than expected.
A donor refusing reasonable information about the source of funds.
Funds originating from unusual or unexplained sources.
Payments made through unrelated third parties.
Repeated transactions designed to avoid internal review thresholds.
A request to return funds to a different person or account.
Donations accompanied by unusual financial arrangements.

13. Cash Donations

Cash donations must be handled through appropriate internal controls.

Where cash is accepted:

A receipt should be issued where appropriate.
Cash should be recorded accurately.
Two-person verification should be used for significant cash collections where practicable.
Cash should be deposited into an authorized organizational bank account promptly.
Personal bank accounts must not be used to hold Jamia tul Mastwaar funds.
Cash records should be reconciled with accounting records.

Jamia tul Mastwaar may establish internal limits for cash transactions based on its activities and applicable legal requirements.

14. Bank Accounts

Jamia tul Mastwaar funds should be maintained in authorized organizational bank accounts.

Employees, volunteers and representatives must not:

Use personal bank accounts for organizational funds without exceptional authorization and appropriate controls.
Transfer organizational money to unauthorized accounts.
Share banking credentials.
Make unauthorized withdrawals.
Use organizational funds for personal expenses.

Bank accounts should be subject to appropriate authorization and reconciliation procedures.

15. Online Donations and Payment Platforms

Where online donation facilities are used, Jamia tul Mastwaar will seek to use reputable and appropriately regulated payment providers.

The organization will maintain appropriate records of:

Donation amount.
Date.
Payment method.
Transaction reference.
Donor information where available and appropriate.

Payment systems should be configured to reduce the risk of unauthorized transactions and fraudulent activity.

16. Zakat and Sadaqah

Jamia tul Mastwaar will maintain appropriate records for Zakat and Sadaqah funds.

Where funds are specifically designated for Zakat or another restricted purpose, they should be:

Recorded separately where appropriate.
Used only for permissible and authorized purposes.
Subject to appropriate financial oversight.
Included in relevant financial reporting.

The organization should ensure that its Zakat collection and distribution practices comply with applicable religious requirements and relevant laws.

17. Grants and Institutional Funding

Before accepting significant grants or institutional funding, Jamia tul Mastwaar may conduct appropriate due diligence on the donor organization or funding body.

The organization may review:

Identity of the funding organization.
Nature and purpose of the funding.
Funding agreement.
Conditions attached to the grant.
Source of funds where appropriate.
Any relevant sanctions or regulatory concerns.

Grant funds must be used according to the agreed purpose and applicable requirements.

18. Third-Party Fundraising

Individuals or organizations fundraising on behalf of Jamia tul Mastwaar must receive appropriate authorization.

Fundraisers should:

Clearly identify themselves as authorized representatives.
Use approved fundraising materials.
Maintain accurate records.
Deposit collected funds through approved channels.
Not misrepresent the purpose of fundraising.

Jamia tul Mastwaar may withdraw authorization from any fundraiser who violates this policy.

19. Prohibited Transactions

Jamia tul Mastwaar will not knowingly participate in transactions involving:

Proceeds of criminal activity.
Terrorist financing.
Fraud.
Bribery or corruption.
Sanctioned or prohibited persons or organizations where applicable.
Concealment of the beneficial owner or source of funds.
False financial documentation.
Transactions designed to evade legal or regulatory requirements.

Where a transaction presents an unacceptable risk, Jamia tul Mastwaar may refuse, suspend or return the funds, subject to applicable law and professional advice.

20. Sanctions Screening

Where appropriate and proportionate to the organization's activities, Jamia tul Mastwaar may screen donors, partners, vendors and other relevant parties against applicable sanctions or prohibited-party lists.

Particular attention may be given to:

Significant donors.
International donors.
Institutional partners.
International transfers.
Higher-risk transactions.

Potential matches should be reviewed carefully before any action is taken, because similar names do not necessarily indicate that two individuals or organizations are the same.

21. Suspicious Transactions

A transaction may be considered suspicious when there are reasonable grounds to believe that it may involve:

Criminal proceeds.
Money laundering.
Terrorist financing.
Fraud.
Unlawful financial activity.
Attempts to conceal the source or destination of funds.
Attempts to circumvent applicable controls.

Examples include:

Large unexplained donations.
Multiple unusual donations apparently structured to avoid review.
Requests to transfer money to unrelated third parties.
Donations followed by unusual refund requests.
Donors who refuse reasonable due diligence.
Transactions inconsistent with the stated purpose of the organization.
Unusual cross-border transactions without a reasonable explanation.

A suspicious transaction does not automatically mean that a crime has occurred. It should be reviewed objectively and, where necessary, escalated appropriately.

22. Reporting Suspicious Activity

Employees and representatives who identify a potentially suspicious transaction should report it promptly to the AML/Compliance Officer or designated management representative.

They should provide:

Date of transaction.
Amount.
Parties involved.
Payment method.
Relevant documentation.
Reason for concern.
Any supporting information.

Where required by law, the organization will make appropriate reports to the relevant competent authorities.

Employees must not attempt to investigate criminal matters themselves.

23. No Tipping-Off

Where a matter has been identified for confidential compliance review or reporting to an authority, employees must not disclose confidential information in a manner that could compromise an investigation or regulatory process.

Information should only be shared with authorized persons who have a legitimate need to know.

24. Financial Controls

Jamia tul Mastwaar will maintain appropriate financial controls, including where applicable:

Segregation of financial duties.
Authorization of payments.
Bank reconciliation.
Donation records.
Expense documentation.
Receipt systems.
Budget controls.
Periodic financial reviews.
Appropriate audit or independent review.
Secure financial record keeping.

No single individual should have unrestricted control over significant financial transactions where practical controls can reasonably be implemented.

25. Record Keeping

Jamia tul Mastwaar will maintain appropriate records relating to:

Donations.
Grants.
Bank transactions.
Cash collections.
Expenses.
Financial approvals.
Donor due diligence where conducted.
Suspicious transaction reviews.
Relevant compliance actions.

Records should be accurate, secure and retained for the period required by applicable law and organizational requirements.

26. Fraud and Corruption

AML controls are part of Jamia tul Mastwaar's broader commitment to financial integrity.

Employees and representatives must not:

Misappropriate organizational funds.
Create false receipts or invoices.
Accept unauthorized personal payments.
Manipulate financial records.
Conceal organizational transactions.
Use organizational resources for personal financial gain.
Offer or accept bribes.

Suspected fraud or corruption must be reported through the appropriate internal reporting mechanism.

27. Conflicts of Interest

Employees, management and representatives must disclose any personal or financial interests that could affect their judgment in financial decisions involving Jamia tul Mastwaar.

Financial transactions involving related parties should be appropriately disclosed, authorized and documented.

28. Staff Training

Relevant staff and volunteers should receive appropriate awareness training covering:

Money laundering risks.
Terrorist financing risks.
Financial fraud.
Donor due diligence.
Suspicious transactions.
Record keeping.
Internal reporting procedures.
Confidentiality.
Financial controls.

Additional training may be provided to staff with direct responsibility for financial management or fundraising.

29. Protection for Whistleblowers

Jamia tul Mastwaar encourages employees, volunteers and other representatives to raise genuine concerns about financial misconduct.

No person should be subjected to retaliation, harassment or discrimination for making a genuine report in good faith.

Reports will be handled as confidentially as reasonably possible.

30. Data Protection and Confidentiality

Personal and financial information collected for AML and financial-control purposes must be handled securely.

Access should be limited to authorized persons.

Information should not be disclosed unnecessarily and should be retained only for the period required by applicable law or legitimate organizational purposes.

31. Risk-Based Approach

Jamia tul Mastwaar recognizes that not all transactions present the same level of risk.

The organization will apply proportionate controls based on factors such as:

Value of the transaction.
Source of funds.
Donor or partner profile.
Geographic considerations.
Payment method.
Purpose of the transaction.
Unusual or unexplained circumstances.
Relevant legal or regulatory requirements.

Higher-risk situations may require enhanced due diligence and management approval.

32. Monitoring and Review

The organization will periodically review its financial activities and AML controls to identify weaknesses or emerging risks.

Reviews may include:

Donation reviews.
Bank reconciliation.
Financial audits.
Review of unusual transactions.
Review of high-value funding.
Sanctions screening where appropriate.
Internal control assessments.

Where weaknesses are identified, corrective measures should be implemented.

33. Breach of Policy

Failure to comply with this policy may result in:

Internal investigation.
Disciplinary action.
Suspension of relevant responsibilities.
Termination of employment or engagement where appropriate.
Referral to competent authorities where required.

Serious breaches may also result in civil or criminal consequences under applicable law.

34. Policy Review

This policy will be reviewed at least every two years, or sooner if:

Relevant legislation changes.
Jamia tul Mastwaar's activities change significantly.
New financial services or donation methods are introduced.
A significant financial incident occurs.
A regulatory requirement changes.
A risk assessment identifies new risks.

Next Review Date: __________________________

35. Management Approval

This Anti-Money Laundering Policy has been reviewed and approved by the authorized management of Jamia tul Mastwaar.

Authorized Person: __________________________

Designation: _______________________________

Signature: __________________________________

Date: ______________________________________

Official Stamp: ______________________________