Policy on Sending Money Abroad
This policy was developed and adopted by the trustees on 11/11/24
It will be reviewed regularly and amended in the light of current regulations
Purpose
As a small charity, Community Action Ghana is committed to ensuring that our financial operations adhere to the highest standards of transparency and legality. This policy outlines our approach to sending funds to Ghana, ensuring compliance with relevant UK laws and regulations, including guidance from the Charity Commission and the Information Commissioner’s Office (ICO).
Scope
This policy applies to all trustees of our charity who are involved in the process of sending money overseas. If we in the future have volunteers or employees, it will apply to them as well. It encompasses all methods of transfer, including bank transfers, online payment platforms, and any other means of transmitting funds including transfer to mobile money.
Legal Compliance
Our charity is dedicated to full compliance with all applicable laws and regulations when transferring funds internationally. This includes:
- Charity Commission Guidelines: We will ensure that any money sent abroad is for charitable purposes and that such activities align with our mission and objectives as outlined in our governing documents. We will seek to secure any necessary permissions or registrations as required by the Charity Commission for charitable activities conducted outside the UK.
- Financial Regulations: We will comply with the UK’s Counter-Terrorism Financing and Anti-Money Laundering Regulations. Before sending money abroad, our charity will carry out appropriate due diligence on the recipient and where appropriate, recipient organisations. This will include verifying their legitimacy and ensuring that they operate in accordance with applicable laws and regulations in Ghana.
- Tax Laws: We will ensure compliance with HM Revenue and Customs (HMRC) requirements regarding the remittance of any funds, including tax obligations, to avoid potential penalties.
Transparency and Oversight
To maintain the integrity of our financial operations, all international money transfers will be documented and reported to our board of trustees. The following measures will be implemented:
- Approval Process: All requests to send money abroad must be documented through a formal request process. This includes justification for the transfer, details of the recipient organisation, and the purpose for which the funds will be used.
- Record Keeping: We will maintain comprehensive records of all transactions, including copies of transfer documentation, correspondence with recipient or recipient organisations, and any relevant approvals. This information will be retained in accordance with our data retention policy and accessible for auditing purposes.
- Reporting: We will provide regular reports to the board of trustees detailing the funds transferred abroad, including the recipient or recipient organisations, amounts sent, and the intended use of the funds. This ensures a continuous overview of our international financial activities.
Data Protection
In compliance with the UK General Data Protection Regulation (GDPR), we will ensure that any personal data associated with international transfers is managed responsibly. This includes:
- Data Minimisation: We will only collect and retain personal information that is necessary for the transaction and for our legal obligations.
- Secure Transfer: All personal data exchanged with international partners will be transmitted securely, adhering to best practices for data protection.
- Privacy Notices: We will provide all relevant parties with information about how their data will be used, ensuring transparency and fostering trust.
Monitoring and Review
This policy will be reviewed annually by the board of trustees to ensure its effectiveness and compliance with changing laws and regulations. Any necessary amendments will be implemented promptly to reflect best practices in financial governance and international transfers.
Conclusion
Our charity is dedicated to upholding the principles of accountability and transparency in all our financial dealings, particularly those involving international transactions. By adhering to this policy, we aim to ensure that our operations remain ethical and compliant with both UK law and the intentions of our supporters, maximising the impact of the charitable donations we distribute globally.
