COUNTER-TERRORISM FINANCING (CTF) POLICY

GLOBAL UNION OF CHANGEMAKERS (GUC)

Purpose

GUC is committed to preventing the misuse of its funds, resources, programs, and partnerships for the purposes of terrorism or terrorist financing. This policy ensures compliance with international standards, including:

Financial Action Task Force (FATF) Recommendations

United Nations Security Council Resolutions (UNSCRs) on counter-terrorism

National Anti-Terrorism Financing laws

This policy protects GUC’s integrity, reputation, and ability to operate globally while safeguarding the communities it serves.

Scope

This policy applies to:

All Board members, staff, volunteers, interns, consultants, and contractors;

All financial transactions, donations, grants, and resource transfers;

All partners, sub-grantees, and collaborators of GUC;

All programs, activities, and operations where financial or in-kind resources are used.

Guiding Principles

Zero Tolerance: GUC maintains a strict zero-tolerance approach to terrorism financing and activities supporting terrorism.

Compliance: All activities comply with applicable international and national laws, regulations, and sanctions regimes.

Transparency & Accountability: All financial transactions are recorded, monitored, and auditable.

Due Diligence: Robust screening of donors, partners, and financial transactions to prevent misuse of funds.

Staff Awareness: GUC ensures all personnel are trained and aware of CTF obligations and reporting procedures.

4. Organizational Responsibilities

4.1 Board & Leadership

Approve and oversee implementation of the CTF Policy;

Ensure organizational resources and programs comply with CTF standards;

Monitor risk management strategies to prevent terrorism financing exposure.

4.2 Management & Finance Staff

Implement financial controls, due diligence, and reporting mechanisms;

Conduct regular risk assessments on programs, partners, and donors;

Maintain transparent records and report suspicious activities to the Board and, where required, relevant authorities.

4.3 Staff, Volunteers & Partners

Comply with all CTF procedures;

Report any concerns or suspicious activities immediately through internal reporting channels;

Participate in training on counter-terrorism financing.

Due Diligence & Screening Procedures

Donor & Partner Screening:

Verify identities of donors, partners, and beneficiaries;

Screen against UN, FATF, and national sanctions lists;

Refuse funding or partnerships if risk of terrorism financing is detected.

Financial Transaction Monitoring:

All incoming and outgoing funds are documented, traceable, and auditable;

Transactions above set thresholds require enhanced scrutiny;

Monitor irregular patterns, unusual requests, or high-risk geographies.

Sub-grantee & Program Monitoring:

Ensure all sub-grantees and local implementing partners adhere to CTF standards;

Include CTF clauses in contracts, MOUs, and funding agreements;

Conduct periodic audits and site visits.

Reporting & Whistleblowing

GUC maintains confidential reporting channels for staff, volunteers, or partners to report suspicious activity;

Reports are investigated promptly and discreetly;

Findings are reported to relevant regulatory authorities as required by law;

Retaliation against individuals reporting in good faith is strictly prohibited.

Training & Awareness

Regular CTF training is mandatory for staff, volunteers, finance personnel, and partners;

Awareness campaigns highlight risks, red flags, and reporting obligations;

Training ensures alignment with global non-profit sector standards and donor requirements.

Review & Continuous Improvement

• This policy is reviewed at least annually, or sooner in response to:

• Changes in law, UN resolutions, or FATF guidelines;

• Findings from audits or risk assessments;

• Lessons learned from programmatic experience or partner reviews.

• Updates are communicated to all staff, partners, and relevant stakeholders.

Approval

This Counter-Terrorism Financing Policy is approved by the Executive Director and Board of GUC, affirming the organization’s commitment to preventing terrorism financing, protecting its resources, and safeguarding communities