Anti-Fraud & Anti-Money Laundering (AML) Policy

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Radical Outreach
Last Updated: December 2025

1. Purpose of This Policy

Radical Outreach is committed to maintaining the highest level of financial integrity, donor trust, and organizational accountability. As a U.S.-based nonprofit working globally—often in regions with elevated risk of fraud, corruption, and financial exploitation—we take deliberate measures to prevent, detect, and respond to fraudulent activity and money laundering.

The objectives of this policy are to:

• Safeguard donor funds
• Protect the organization’s reputation
• Ensure compliance with U.S. laws and international standards
• Detect and prevent fraud, corruption, and financial abuses
• Ensure transparency and ethical stewardship of all resources

2. Scope

This policy applies to:

• All employees, including leadership and administrative staff
• Volunteers, interns, and field workers
• Board members and officers
• Contractors, consultants, and financial service providers
• International partners, local ministries, and field project coordinators
• Any individual handling funds or financial information on behalf of Radical Outreach

3. Definitions

3.1 Fraud

Fraud includes any intentional act of deception for financial or personal gain, such as:

• Theft or embezzlement
• Forgery or alteration of documents
• Misuse of donor funds
• False reporting of expenses or program activities
• Misrepresentation of financial information
• 
  

3.2 Money Laundering

Money laundering refers to attempts to disguise the origin of illegally obtained funds by passing them through legitimate channels, including charitable organizations.

3.3 Suspicious Activity

Activity that may indicate fraud, corruption, or money laundering, including unusual donation patterns, unverifiable donors, or transactions inconsistent with normal giving behavior.

4. Organizational Commitment

Radical Outreach commits to:

• Maintaining strong internal controls
• Ensuring transparent financial reporting
• Training staff and volunteers in anti-fraud principles
• Monitoring all financial transactions
• Cooperating fully with governmental authorities

Fraud, corruption, bribery, and money laundering are strictly prohibited and may lead to dismissal, legal action, or reporting to law enforcement.

5. Internal Controls and Prevention Measures

5.1 Financial Segregation of Duties

To reduce risk:

• No single individual may control all phases of a financial transaction
• Spending authority is clearly defined
• Dual review is required for large or international transactions

5.2 Training and Awareness

All individuals with financial responsibilities must receive periodic training on:

• Fraud prevention
• AML awareness
• Identifying suspicious activity
• Reporting procedures

5.3 Financial Documentation

All donations, grants, disbursements, and international transfers must be:

• Properly documented
• Recorded in secure financial systems
• Traceable and auditable

6. Monitoring and Detection

Radical Outreach actively monitors financial activity for:

• Unusual or unusually large donations
• Donations from high-risk countries
• Gifts made with conditions that appear suspicious
• Inconsistencies in donor identity or contact information
• Multiple donations using the same payment source but different names
• Requests to redirect funds to third parties or unrelated entities
• Attempts to influence financial decisions improperly

We may place holds on transactions that require further review.

7. Donor Due Diligence & Verification

Under certain circumstances—particularly when required by U.S. law, IRS guidelines, or financial compliance standards—we may request additional documentation from donors to verify:

• Identity
• Source of funds
• Legitimacy of the gift
• Compliance with U.S. sanctions, embargoes, or anti-terrorism regulations (OFAC)

Donors who refuse verification may have their contributions declined or refunded.

8. International Transactions

Because Radical Outreach operates globally:

• Transfers of funds to international partners require documented approval
• Partners must confirm that funds are used exclusively for charitable purposes
• Partners must acknowledge their responsibility to prevent bribery, fraud, or diversion
• Disbursements may be suspended if documentation is insufficient

9. Reporting Procedures

9.1 Internal Reporting

Anyone who suspects fraud or AML violations must report concerns immediately to:
[Insert Compliance or Finance Email]
or
[Insert Board Treasurer / Audit Committee Contact]

Reports may be made confidentially and are protected under our Whistleblowing Policy.

9.2 External Reporting

Radical Outreach complies with required U.S. reporting to:

• IRS (suspected misuse of charitable assets)
• FinCEN (Financial Crimes Enforcement Network)
• OFAC (Office of Foreign Assets Control) for sanctions-related concerns
• Local or federal law enforcement, when applicable

Failure to report suspicious activity may result in disciplinary action.

10. Investigation Process

• All reports will be promptly reviewed
• Investigations may include reviewing financial records, interviewing parties, and      consulting legal or compliance experts
• Individuals under investigation may be temporarily suspended from duties
• Findings will be documented and corrective action implemented

Corrective action may include:

• Termination of employment or partnership
• Legal action or prosecution
• Policy or procedural revisions

11. Protection from Retaliation

No whistleblower or staff member will experience retaliation for reporting concerns made in good faith. Retaliation may result in disciplinary action up to and including termination.

12. Record Keeping

Radical Outreach will maintain all documentation related to:

• Suspicious activity reports
• Investigations
• Training records
• AML checks

Records will be securely stored in accordance with U.S. nonprofit standards.

13. Policy Review

This policy will be reviewed annually by the Board of Directors or its assigned Audit/Finance Committee to ensure compliance with evolving U.S. regulations and international best practices.