Anti Money Laundering and Counter Terrorist Financing Policy and Commitment Statement

Last updated: September 2026

ARUSi will not knowingly receive, hold, transfer or use criminal property, conceal the source or ownership of funds, or support money laundering, terrorism financing or proliferation financing. We apply controls proportionate to our services, partnerships, sponsorships, procurement and payment channels.

1. Scope and legal position

This policy applies to directors, employees, finance and programme personnel, consultants, agents and contractors handling ARUSi funds, property, records or counterparties. ARUSi will comply with the Proceeds of Crime and Anti-Money Laundering Act, applicable regulations, sanctions and lawful directions. If ARUSi is designated or otherwise falls within a regulated reporting category, it will implement all additional duties that apply to that status. This policy does not claim that ARUSi is currently a reporting institution.

2. Risk based checks

Before a material or higher-risk relationship or transaction, ARUSi will take reasonable steps to identify the counterparty, understand the purpose of the relationship, verify relevant registration and beneficial ownership, identify authorised representatives, consider conflicts and screen for credible adverse information or applicable sanctions.
Enhanced review is required for unusual complexity, opaque ownership, politically exposed persons or close associates, high-risk locations, unexplained third-party payments, cash-intensive arrangements, inconsistent documents, or transactions without a clear connection to ARUSi's work. Approval must be independent of the person who introduced the counterparty where practicable.
ARUSi will accept and make payments through traceable channels in the organisation's or legitimate counterparty's name wherever practicable. Cash use must be limited, authorised, receipted, reconciled and supported by a legitimate programme purpose. Personal accounts, split payments designed to avoid controls, false descriptions, unexplained refunds and overpayments followed by redirection are prohibited.
Donations, grants and sponsorships must have documented source, purpose, conditions, budget, approval and reporting. Procurement payments must correspond to a verified supplier, contract or purchase record, delivery evidence and approved invoice.

3. Warning signs and escalation

Warning signs include reluctance to identify owners, unexplained urgency or secrecy, mismatched payer and beneficiary, requests to return money elsewhere, unusually large cash payments, inconsistent invoices, no credible service, unexplained foreign routing, or a counterparty whose explanation does not fit the transaction. Personnel must pause the transaction where safe and lawful, preserve records and refer the concern to management. They must not alert a person that a report or investigation is being considered where doing so may prejudice lawful action.

4. Reporting and cooperation

ARUSi will assess concerns confidentially and seek legal or professional advice when needed. Where law requires or the circumstances justify it, ARUSi will report to the Financial Reporting Centre, police or another competent authority and cooperate with lawful requests. No person will suffer retaliation for a good-faith report. A knowingly false or malicious allegation may be addressed under applicable disciplinary rules.

5. Records training and review

ARUSi will keep due-diligence, approval, contract, transaction and investigation records securely for the period required by law and legitimate contractual needs. Access will be limited and personal data handled lawfully. Relevant personnel will receive practical training. Management will review the effectiveness of controls, especially after a significant incident, new funding model, new country exposure or legal change.

6. Reporting a Concern

Concerns may be raised with a supervisor, a member of management or legal@arusi.ke with the subject Confidential financial integrity concern. Urgent criminal or terrorism-related concerns should also be reported to the appropriate Kenyan authority.

7. Applicable Kenyan Law

This policy is governed by the laws of the Republic of Kenya and will be interpreted consistently with all mandatory legal and regulatory requirements that apply to ARUSi. Relevant references include:

If this policy conflicts with a mandatory legal requirement, that requirement will prevail and ARUSi will update the policy as necessary.

8. Contact Us

If you have questions about this policy or wish to report a concern, please contact us:

Email: legal@arusi.ke
Address: P.O. Box 64469-00620, Nairobi, Kenya
Phone: +254 709 700 500