PHIG Policy Framework v1.2 · Policy 19 · Adopted 1 September 2026 · References: ASF Policy 6; Directive (EU) 2015/849 and (EU) 2018/843; FATF Recommendation 8 (non-profit organisations); USAID anti-terrorism certification and E.O. 13224; Georgian AML law
1. Purpose and scope
To ensure that PHIG is never used to launder money or finance terrorism, and that it can certify this to donors. Applies to the Board, the Director, staff, consultants, volunteers, experts, partners and suppliers of PHIG and all platforms of its network.
2. Policy
- Know your donor, partner, sub-grantee and supplier: identity, ownership and source of funds established and recorded before funds are accepted or transferred.
- No cash receipts above EUR 200; no cash payments above EUR 200; all other transactions through PHIG’s bank accounts.
- All counterparties screened against EU, UN, US (OFAC SDN) and UK sanctions and terrorist lists before engagement and at least annually (see Sanctions Policy).
- Funds transferred only to the verified bank account of the contracted entity; no third-party payments; no transfers to jurisdictions where prohibited.
- Unusual transactions — unexplained donors, round-trip payments, requests to route funds through intermediaries, refusal to provide identity — are refused and reported to the Director and, where required by law, to the Financial Monitoring Service of Georgia.
- PHIG signs donors’ anti-terrorism certifications only after verifying that the policy has been applied to the action concerned.
- Sub-grantees and partners adopt equivalent rules by contract.
3. Procedures
- AML checklist in every partnership and sub-award file; annual AML review reported to the Board.
Responsibilities
Director; accountant; Board.
Review
Every two years and when donor rules change.
Part of the PHIG Policy Framework. Breaches and concerns may be reported under the Whistleblowing Procedure to info@accreditation.ge (subject “Confidential — integrity”).