AML & KYC Policy

AML / CFT Policy

• 1. Objective

  The AML/CFT Policy of SINA is designed to prevent and detect money laundering and terrorist financing activities.
  It provides guidance to SINA Board members, management, and staff on procedures to identify, assess, and manage AML/CFT risks.
  The policy is aligned with AML/CFT laws and regulations of Pakistan and applies to all SINA employees, volunteers, and related parties.
  The policy is grounded on two core pillars: compliance and safeguard, with the following objectives:

  • • To comply with all laws, rules, and regulations as mentioned in clause 2 of this policy.
  • • To safeguard SINA from reputational risks and regulatory breaches, and to protect the Foundation, its donors, beneficiaries, employees and stakeholders from ML/FT exposure.

• 2. Responsibility

  Responsible parties:

  • a) Board of Directors
  • b) Board Audit & Risk Committee
  • c) Entire staff of SINA

• 3. Policy

  SINA and its staff commit to abide by applicable AML/CFT laws and regulations. SINA will establish measures to prevent and detect money laundering,
  terrorist financing, and other illegal activities. Procedures will be developed to identify, manage and control ML/TF risks.

  3.1 Adoption of Guidelines on Good Practices for AML/CFT

  The following SECP-recommended guidelines have been adopted by SINA to ensure transparency and mitigate ML/TF risks:

  • 3.1.1 Adoption of Best Practices
    
    • 3.1.1.1 SINA conducts a risk assessment using a risk assessment matrix to identify and evaluate ML/TF risks and implements measures to mitigate them.
    • 3.1.1.2 SINA refrains from activities that breach security, contradict Pakistan’s national interest or government policies, or involve anti‑state activities.
    • 3.1.1.3 SINA uses collected research data solely to promote its objectives.
    • 3.1.1.4 Annual AML/CFT training is provided to employees and records of such training are maintained.
    • 3.1.1.5 SINA is a law‑abiding, non‑political organization with zero tolerance for AML/CFT non‑compliance.
    • 3.1.1.6 SINA follows best practices in financial accounting and prepares financial statements in accordance with applicable standards:
      
      • 3.1.1.6.1 International Financial Reporting Standards (IFRSs) as notified under the Companies Act 2017.
      • 3.1.1.6.2 Standards issued by the Institute of Chartered Accountants of Pakistan (ICAP) for NPOs as notified under the Companies Act 2017.
      • 3.1.1.6.3 Provisions or directives under the Companies Act 2017 prevail where they differ from IFRS or ICAP standards.
  • 3.1.2 Good Governance
    
    • 3.1.2.1 SINA has established an Audit & Risk Committee and an HR & Nomination Committee to oversee risk and compliance.
    • 3.1.2.2 This policy is publicly available on SINA’s website and communicated to all employees.
    • 3.1.2.3 Management is establishing an independent compliance function to achieve AML/CFT objectives.
  • 3.1.3 Due Diligence
    
    • 3.1.3.1 SINA shall take reasonable steps to ensure it:
      
      • 3.1.3.1.1 Knows its donors (“Know Your Donor” or “KYD”).
      • 3.1.3.1.2 Knows its beneficiaries.
      • 3.1.3.1.3 Knows its employees and volunteers.
      • 3.1.3.1.4 Knows the third parties it works with.
      • 3.1.3.1.5 Regularly checks that beneficiaries, employees, volunteers, and third parties are not proscribed individuals or organizations under Pakistan law.
  • 3.1.4 Donor’s Record Retention
    

    Copies of donor identification and any enhanced due diligence records will be retained for the period prescribed by law.

  • 3.1.5 Level of Significance
    

    Any instance of ML or FT is treated as high risk and will not be tolerated.

  • 3.1.6 Effective Risk Management
    

    SINA manages ML/FT risks via controls including a Board‑approved AML/CFT policy, documented procedures, risk registers, ongoing monitoring of funds, and reporting mechanisms.

  • 3.1.7 Internal Control
    

    SINA has an outsourced internal audit function that reports to the BARC and ensures monitoring mechanisms are in place to meet AML/CFT objectives.

  • 3.1.8 Policy Review
    

    SINA shall review this policy and related procedures at least once every two years and update promptly when laws or regulations change.