Antiterrorism policy

Introduction

1. WU renounces all forms of terrorism and will never knowingly support, tolerate or encourage terrorism or the activities of those who embrace terrorism and will make every effort to ensure that its resources are not used to facilitate terrorist activity.
2. This policy sets out WU’s response to the risk of dealing with individuals and organisations associated with terrorism and government legislation associated with this.
3. Failure to comply with government requirements could significantly impact the reputation of WU as well as expose it to risk of penalties.

Legal requirements

1. When WU conducts activities in foreign countries, it will check the Office of Foreign Assets Control ("OFAC") list of Specially Designated Nationals and Blocked Persons for names of individuals and entities with whom we are dealing to determine whether or not they are on the list.
2. WU will have an auditable system of procedures and documentation to prevent foreign expenditures and funds from being diverted to terrorism or other non-charitable activities.
3. WU will comply with all United States statutes, executive orders, and regulations that restrict U.S. persons from engaging in transactions or dealings with designated countries, entities, or individuals or otherwise engaging in activities in violation of economic sanctions administered by the OFAC.
4. WU will acquire from OFAC the appropriate license and registration where necessary.

Policy

1. WU acknowledges that government legislation prohibits dealing with listed terrorist organizations and/or proscribed persons or entities. WU will at all times adopt measures intended to facilitate compliance with this legislation.
2. WU will confirm the identity, credentials and good standing of the people or organisations it supports and will check that these people or organisations are not on the lists maintained by the US government.
3. WU will not knowingly remit any funds to known or suspected terrorist organisations or individuals.
4. WU will report any known or suspected terrorist links to the relevant national authority.
5. WU will use its best endeavours to ensure that overseas recipients of WU’s funds will adopt policies and procedures that enable them to comply with relevant US anti-terrorist legislation.
6. Responsibilities
1. The WU Board is committed to compliance with anti-terrorist legislation to avoid dealing with individuals and organisations associated with terrorism.
2. The Principal will be responsible for ensuring that WU employees carry out the following procedures at least annually to minimise the risk of dealing with terrorist organisations.

Procedures

1. WU staff members must know the identity, credentials and good standing of their partners and recipient organisations (i.e. what they do, where they operate, who are their key decision makers and staff).
2. Care will be taken to only transmit WU funds using reputable banks and other financial institutions for this purpose.
3. To the extent possible, all WU’s ministry and project partners will be made aware of WU’s obligations under law and undertake to adopt similar measures in respect of funds from sources.
4. WU will immediately withdraw all support, including provision of resources, if it has reason to believe that a ministry or project partner has breached the requirements of this policy.
5. As far as practicable, any funding agreement will include wording that requires the recipient organisation to adopt policies and procedures consistent with Government requirements. The suggested wording is:
• "WU acknowledges the international counter-terrorism Treaties and UN Security Council Resolution 1373 (2001) of not providing direct or indirect support or resources to organizations and individuals associated with terrorism.
• WU must use its best endeavours to ensure that funding provided under this Agreement is expended in a manner consistent with the UN Security Council Resolution and related US laws. If, during the course of this Agreement, the Organisation discovers any link whatsoever with any organisation or individual associated with terrorism it must immediately inform the the appropriate US government authorities."

References

1. Relevant legislation can be found in Part 4 of the Charter of United Nations Act 1945 ('the UN Charter Act')
   1. Funding recipients will be required to provide detailed accounting report(s) showing how funds have been spent, at least annually. The accounting report(s) should be subject to an independent review or audit to confirm truth and accuracy of the accounting report.
   2. Prior to funding any organisation, details of funded entities and their office bearers will be compared to government lists of terrorists and proscribed organisations.
2. Where the number of fund recipients is large, consider applying to use LinkMatchLite software to partially automate this task (see link above for information on LinkMatchLite)
3. Where recipient organisations or individuals are found to be on either list, forwarding funds will cease and the national security authorities will be informed immediately.

Guidelines for Strengthening Counter-Terrorism Measures

http://aid.dfat.gov.au/Publications/Pages/3068_5667_7689_8674_4936.aspx
UK Charity Commission - Compliance Toolkit: Protecting Charities from Harm, found at: http://www.charitycommission.gov.uk/Our_regulatory_activity/Counter_terrorism_work/Compliance_toolkit_index.aspx