Part of the PHIG policy framework. Download the full manual (PDF). To raise a concern: admin@accreditation.ge.
PHIG will not let its accounts, grants or partners be used to hide the origin of criminal money or to finance terrorism. Owner: Ethics and Compliance Officer (Irakli Pshinashvili).
Legal framework: the Law of Georgia on Facilitating the Prevention of Money Laundering and Terrorism Financing, EU anti-money-laundering rules and the requirements of each donor. Suspicious activity is reported to the Financial Monitoring Service of Georgia through PHIG’s bank where the law requires.
Controls
- Know your donor and partner: identity, beneficial ownership and sanctions checks before any agreement (Policies 4 and 7).
- Banking only: all income and payments over 500 GEL go through PHIG’s registered bank accounts. Cash is limited to a petty-cash float of 1,000 GEL, reconciled monthly.
- No third-party payments: PHIG pays only the entity that supplied the goods or services, into an account in that entity’s name.
- Refunds: returned only to the original payer and account.
- Records: kept for at least six years after the end of the project or longer if a donor requires.
Warning signs
- A donor or partner reluctant to reveal ownership or source of funds.
- Offers to overpay and ask for a refund, or to pay through a third party or another country.
- Requests to route funds through PHIG for an unrelated purpose.
- Transactions with no clear programme purpose or with high-risk jurisdictions.
Reporting
Any suspicion goes to the Ethics and Compliance Officer the same day. Do not warn the person involved (“tipping off”). The Officer decides, with the Head of Administration, whether to report to the bank and authorities and to donors (Policy 15).