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ANTI-MONEY LAUNDERING POLICY

Policy/Procedures

Money laundering is conducting or attempting to conduct a financial transaction knowing that the transaction is designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of specified unlawful activity. To assist the federal government in detecting, preventing, and eradicating criminal and terrorist financing and activity, the university will take all necessary steps to comply with applicable anti-money laundering laws and regulations.

The university will maintain an anti-money laundering program in accordance with the Bank Secrecy Act, as amended by the USA PATRIOT Act, and other applicable federal laws and regulations. The program is reasonably designed to prevent university services from being used to facilitate money laundering and the financing of terrorist activities. The program includes the following:

•Procedures to verify customer identification and retain necessary identifying and transactional information;

•A designated compliance officer to coordinate compliance with the program;

•Suspicious activity reporting procedures and document retention guidelines for any suspicious activity reports and supporting documentation;

•Training and education of appropriate university personnel concerning their responsibilities under the program, including suspicious activity reporting; and

•Independent review to monitor and maintain an adequate program.

Concerns regarding transactions that are unusually large or that appear suspicious and questions regarding money laundering in general should be directed to the university’s Treasury Management Office at 202-994-0985.

Website Address for This Policy

GW University Policies

Contacts

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ANTI-MONEY LAUNDERING POLICY

Related Information

Bank Secrecy Act, 12 U.S.C. §1951, et seq.

31 U.S.C. § 5311, et seq.

31 C.F.R. Part 1010, 1022

Money Laundering Control Act of 1986, Public Law 99-570 USA PATRIOT Act of 2001, Public Law 107-5

A Brief Primer on Doing Business Abroad: U.S. Laws that Affect GW’s International Activities

Compliance with Law when Conducting University Activities Overseas

Who Approved This Policy

Louis H. Katz, Executive Vice President and Treasurer

Beth Nolan, Senior Vice President and General Counsel

History/Revision Dates

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