Media Defence’s Anti-Money Laundering Policy

Media Defence works to defend media through the application and advance of international human rights standards.

Media Defence is a registered charity and we comply fully with UK charity law and all applicable laws and regulations.

We have a responsibility to ensure adequate controls are in place to ensure our charity funds are

used to pursue our charitable objectives and to safeguarded against a range of potential abuse,

including terrorist financing and money laundering.

i) Ensuring that our assets are safeguarded and properly used to meet our charitable objectives and that our resources are not being used to support criminal or terrorist purposes.

ii) Preventing use of our programmes for money laundering1 or other activities that breach applicable laws.

iii) Reporting suspected money laundering and/or suspected provision of support to terrorist organisations.

This policy applies to Trustees, staff and volunteers.

Policy Statement

Media Defence is committed to ensuring that our activities comply with all applicable laws and regulations relating to money laundering and provision of support to terrorist or criminal organisations.

of money laundering or the financing of terrorism or criminal activities

We actively take measures to prevent the use of Media Defence as a medium for money laundering or the financing of terrorism or criminal activities, and we will report any suspected money laundering or terrorist financing to the appropriate authorities.

Prevention

Media Defence minimises the risk of our activities or funds being used for money laundering or the financing of terrorism or criminal activities by ensuring we verify the source of the funding and donations we receive, and verifying the identity of the organisations/individuals we fund.

Decisions on whether to accept funds from a new source will be taken by Media Defence’s board, after the potential donor has been carefully vetted by the CEO or a delegated authority. We ensure that the organisations/individuals we accept funds from and those what we fund are not on any lists of proscribed terrorist groups or persons, financial sanctions list or other regulatory compliance list.

1 Money laundering is a process by which an individual or organisation attempts to conceal the true origin and ownership of the proceeds of their criminal activity including by means of transfers to/through legitimate businesses and charities.

This includes:

The risks Media Defence raised funds and receives donations, where Media Defence disburses grant funding, and in the provision may arise when of services and other charitable activity. We also carry out the following additional verification steps:

Dispersion of grant funding

We further verify the identity of the journalists/lawyers that we fund and the veracity of their claim/case through desk (internet) research, referrals from known and trusted partners, for example other international human rights organisations, and through supporting documentation from the journalist/lawyer. For example, we require copies of at least one relevant legal document (charge sheet, writ of summons, judgment, etc.) and we search for local, regional or international reporting on the case. To verify that the lawyer in the case is legitimate and is in fact assigned to this case, we require confirmation of the bar status of the lawyer, locate case details on the relevant court or ministry website and require a copy of the power of attorney between the lawyer and the client.

We verify the identity, existence and legitimacy of the Partner Organisations we fund by checking against sanction lists the name of the new partner organisation, its Director, board members (particularly the Chair and Treasurer) and any of their staff to be funded. We also review the organisation’s registration certificate and audited financial statements, and seek references from peer organisations.

Media Defence grants to organisations/individuals are only considered for approval once the applicant has been verified and passed the necessary due diligence checks.

To ensure funds are being used for the purposes for which they are given, Media Defence requires, interim and final reports and case updates before the final tranche of funds is paid out. As part of the terms of any grant awarded, an interim report or update is to be submitted every six months and then a final report, including a copy of the final court judgment and financial report (with invoices and receipts) at the end of the grant period or the conclusion of the legal case. Media Defence also requires updates from grantees by phone or email about the legal cases as they progress, and we monitor progress in the cases through press coverage.

Payments to other stakeholders

Prior to making any payment to other stakeholders, for example consultants and suppliers, the name of the stakeholder is also checked against sanction lists to ensure they are not on any proscribed terrorist groups or persons, financial sanctions or other regulatory compliance lists.

When paying out/settling any liabilities, Media Defence makes payment only into bank accounts with the same name as the lawyer, law firm, journalist or other stakeholder it has entered a relationship with. In cases where payment is requested into an account with a different name to the intended recipient, we require justification, and obtain a government issued/official photo identification of the account holder. We also require authorisation from the intended recipient to pay funds to the account holder and confirmation from the account holder that funds will be transferred to the intended recipient to use for the purpose for which the grant was awarded.

Reporting

Media Defence will report any suspected money laundering or terrorist financing to the National Crime Agency (NCA) by sending a Suspicious Activity Report (SAR).

Policy Review/Update

Media Defence will review this policy annually and update it as necessary to reflect any new legal and regulatory developments.