Anti-Money Laundering Policy

SaveThem India Foundation is committed to preventing money laundering and the financing of terrorism. A charity that moves money between strangers is exactly the kind of organisation somebody would try to use for it, and we would rather turn a donation away than become the route.

This policy sets out the systems and controls we maintain to reduce that risk: who we know we are taking money from, what we will not accept, what we watch for, and what we do when something looks wrong.

• The Prevention of Money-Laundering Act, 2002 and the rules made under it.
• The Unlawful Activities (Prevention) Act, 1967, and the lists of designated persons and entities published under it.
• The Foreign Contribution (Regulation) Act, 2010 and its rules, which govern every rupee we receive from outside India.
• The Income-tax Act, 1961 — in particular the limits on cash receipts and the treatment of anonymous donations to a charitable trust.

Where a rule changes, this policy follows it. Where our own rule is stricter than the law, our own rule applies.

Every trustee, employee, volunteer, intern, consultant and associate of the Foundation, in every office and on every programme. It applies to money coming in, money going out, and goods received in kind. Nobody is outside it because of seniority or because a donor is well known to us.

• The Board and management ensure the Foundation complies with AML law, approve this policy, and give the Compliance Officer the authority and the independence to do the job.
• The AML Compliance Officermonitors compliance, reviews escalated donations, runs training, keeps the records, and makes reports to the authorities. They may hold or return a donation without needing anybody's approval.
• Employees and volunteers follow this policy and report anything that does not look right — promptly, and without deciding for themselves whether it is serious enough.
• Financereconciles every receipt against the gateway's records and against the bank, so that money in the account and donations on the books are the same set of facts.

The Compliance Officer is reachable through support@savethem.in. Mark the subject line AML and it is routed to them directly.

We assess our exposure to money laundering and terrorist financing at least once a year, and again whenever we start a new programme, open a new channel for receiving money, or begin working in a new region. The assessment looks at who gives to us, how they pay, where the money comes from, and where it goes — and the controls in this policy are set against what it finds.

We do not accept anonymous donations. Every donation made through this website carries a name and a working phone number, because that is what the form requires before a payment can begin.

• Payments run through a regulated gateway. Razorpay performs its own KYC on the paying instrument, and a payment we cannot trace to a real card or account does not become a donation.
• A PAN is collected for 80G receipts, which anchors a donor to a verified identity for the donations that claim a deduction.
• Large or unusual donations get a second look. Above the threshold set by the Compliance Officer we ask about the source of funds and record the answer before the donation is applied.
• Institutional and corporate donors are asked for registration details and the identity of the person authorising the payment.
• Names are screened against the lists of designated individuals and entities published under Indian law and by the United Nations. A match is not accepted and is reported.

Due diligence applies at the other end too. Partner institutions, vendors and the organisations we deliver through are verified before money or goods pass to them.

Cash is the hardest money to trace, so we have built the Foundation to need very little of it. This website takes no cash at all.

Where cash is unavoidable in the field, it is receipted on the spot, banked promptly, and recorded against a named giver. We do not accept a cash donation from somebody who will not be named, and we do not accept cash in amounts that Indian tax law does not permit a charity to receive. A donor who wants an 80G deduction is asked to pay digitally, because the deduction is not available on cash above the statutory limit in any case.

Contributions from outside India are accepted only into the designated FCRA account the law requires, only where our FCRA registration is current, and only after the donor and the purpose have been recorded. Foreign money is never mixed with domestic receipts, is never routed through a personal account, and is reported as the Act requires. If you are giving from abroad, please write to support@savethem.in first so it reaches the right account.

A refund is returned to the original card or account only — never in cash, never to a wallet, and never to a third party. This is stated in our Refund Policy as a matter of fairness, and it is enforced here as a control: a charity that refunds to a different account is a way of moving money, and we will not be one.

Any of the following is escalated to the Compliance Officer before the donation is applied to any work:

• A donation that is large relative to what we know of the donor, from somebody who has never given before.
• A donor who shows no interest in what the money is spent on, or who declines to say where it came from.
• A request to refund to a different card, account or person than the one that paid.
• One amount broken into many smaller payments, or many payments from different instruments in one name.
• Payment by a third party, with a receipt requested in somebody else's name.
• Pressure to issue a receipt for more than was actually given, or to backdate one.
• A donation tied to a condition about who the Foundation must pay, employ or contract with.
• Any link, however indirect, to a person or entity on a designated list.

A red flag is not an accusation. Most turn out to be innocent and the donation proceeds; the point is that somebody looked before it did.

Anybody who sees something suspicious reports it to the AML Compliance Officer at once — in writing where possible, and without waiting to be certain. It is not for the person who noticed it to investigate, and it is not for them to judge whether it is serious enough.

Do not tell the donor. Warning somebody that they are being looked at is itself an offence under the Act. The Compliance Officer reviews the report, gathers what is needed, and makes any required report to the Financial Intelligence Unit — India and to any other authority the law names.

Nobody is penalised for reporting in good faith. A report that turns out to be nothing carries no consequence for the person who made it. Failing to report something you noticed does.

We keep accurate and complete records of every transaction, of the identification collected for it, and of every internal report and the decision taken on it — for a minimum of five years, and longer where tax, FCRA or audit rules require. Records are held securely and access is limited to the people whose work needs them. How that information is handled generally is set out in our Privacy Policy.

Everybody who handles donations is trained on this policy when they join, and at least once a year after that — on what the red flags look like, what to do about one, and why telling the donor is not an option. The policy itself is reviewed annually by the Compliance Officer and approved by the Board, and sooner whenever the law or our own risk assessment changes.

To raise a concern under this policy, write to support@savethem.in with AML in the subject line. You may do so anonymously, and it will still be looked at.

This policy sits alongside our Terms of Use, Privacy Policy and Refund Policy.