This policy has been drafted with the intention of defining and formalising the commitment of the ‘Canadian Chamber in Italy’ (hereinafter referred to as ‘the Association’) based in Via Biancamano, 25 – 00185 Rome, in preventing and combating money laundering and terrorist financing. This document reflects our ongoing commitment to operate with integrity and transparency in all our activities, particularly in the acceptance and management of donations.

The main purpose of this policy is twofold: first, to establish clear and effective procedures to identify, assess and manage the risks associated with money laundering and terrorist financing. Secondly, to ensure that the Association operates in full compliance with all relevant national and international AML/CFT laws, regulations and guidelines.

We recognise that money laundering and terrorist financing pose significant threats to the integrity of the global financial system and the security of communities internationally. Therefore, the Association is committed to implementing preventive strategies, control procedures and reporting mechanisms to counter these illicit activities.

Through our anti-money laundering policy, we aim to:

• Establish a robust framework for identifying and verifying the identity of donors and the source of their donations.
• Implement monitoring systems to detect and report any suspicious activity.
• Ensure that all members, employees and volunteers of the Association are properly trained and informed of their roles and responsibilities in relation to the prevention of money laundering and terrorist financing.
• Maintain a high level of compliance with current regulations, adapting our procedures according to legislative changes and industry best practice.

This policy is an essential part of our mission and values, and we are committed to regularly reviewing and updating it to ensure that it remains effective and relevant.

To ensure clarity and consistent understanding of the terms used in this policy, we provide the following definitions:

2.1 Donation: A donation is a voluntary contribution in money, goods or services, without expectation of compensation, direct benefit or consideration. Donations may be made by individuals, companies, government agencies or other organizations.

2.2 Money Laundering: This is the process of transforming the proceeds of criminal activities into apparently legitimate funds or investments. Money laundering is a crime that involves three distinct stages: placement (introduction of illicit proceeds into the financial system), layering (complicating the tracing of proceeds through a series of transactions or conversions), and integration (reintegration of proceeds back into the economic system as ostensibly legitimate funds).

2.3 Terrorist Financing: This refers to any form of financing, direct or indirect, that is used or intended to be used to support terrorist activities. This includes the financing of organisations, individuals or activities that intend to perpetrate acts of terrorism, regardless of the source of the funds.

2.4 Suspicious Donation: A suspicious donation is any financial or other contribution to the Association that raises doubts or concerns as to its origin, purpose or legitimacy. This may include, but is not limited to, donations of an unusually large amount, donations from anonymous sources or from high-risk countries, or donations that are conditioned on or associated with requests that are atypical or not in accordance with the Association’s standard practices.

2.5 Politically Exposed Person (PEP): Refers to individuals who hold or have held important public office, such as Heads of State, senior government officials, political leaders, important leaders of political parties, and senior officials of international organisations. Politically exposed persons are considered high risk in the context of money laundering and terrorist financing because of their position and influence.

2.6 Proceeds of criminal activity: This refers to any property or value derived directly or indirectly from criminal activity. This includes, but is not limited to, gains obtained through drug trafficking, bribery, theft, fraud and other forms of illegal activity.

2.7 Rejection of cash donations: The Canadian Chamber in Italy does not accept cash donations. This policy is adopted to reduce the risk of money laundering and terrorist financing, which is often higher in cash transactions. Instead, we encourage donors to use traceable and transparent payment methods, such as bank transfers, credit card payments, cheques or other forms of electronic payment.

The “Canadian Chamber in Italy” adopts the following fundamental principles in its donation management, to ensure adherence to high ethical and legal standards, as well as to prevent money laundering and terrorist financing:

3.1 Transparency: We are committed to maximum transparency in the collection, management and use of donations. This includes clear and honest communication with donors and a clear indication of how donations are used to achieve the Association’s objectives.

3.2 Responsibility: The Association takes full responsibility for ensuring that all donations are accepted and handled in accordance with applicable laws and regulations, as well as industry best practice. This includes the proper documentation of donations, their registration, and the reporting of any suspicious activity to the relevant authorities, if required by current regulations.

3.3 Integrity: We maintain a firm commitment to integrity in all our operations. This means refusing donations that could result from illegal activities, conflict with our values or compromise our independence or reputation.

3.4 Legal compliance: We are committed to operating in full compliance with local, national and international anti-money laundering and anti-terrorism regulations. This includes regularly updating our policies and procedures to reflect any changes in legislation and regulations.

3.5 Diligence in accepting donations: We carry out appropriate checks to ascertain the origin of donations, especially those exceeding €.1000.00 (one thousand/00 euros) or coming from potentially high-risk sources.

3.6 Training and Awareness: We ensure that our staff and volunteers are trained regularly and are aware of policies and procedures related to money laundering and terrorist financing, as well as their responsibilities in this area.

3.7 Risk management: We proactively assess and manage the risks associated with money laundering and terrorist financing, taking appropriate measures to mitigate these risks.

3.8 Review and continuous improvement: We are committed to periodically reviewing our policy and practices to ensure that they remain effective and relevant, making improvements where necessary.

To assure compliance with anti-money laundering laws and prevent the financing of terrorism, it is essential that the Canadian Chamber in Italy implements effective procedures for identifying and verifying the identity of donors. This chapter outlines the procedures that the Association will follow for each donation received.

4.1 Collection of personal information: For each donation, we will collect basic personal information about the donor. This includes, but is not limited to, full name, address, date of birth, nationality, social security number and telephone number or email. In the case of legal donors (such as companies or entities), we will collect information about the entity, including the entity’s name, registered office address, and details of authorised representatives.

4.2 Verification of identity documents: For individual donors, we will request and verify a valid identity document (such as passport, national identity card). For legal donors, we will request and verify official documentation proving the legal existence of the entity (such as certificate of corporate registration) and identity documents of authorised representatives.

4.3 Checks on sanctions lists and PEPs: We will carry out checks on international and national sanctions lists, drawing information from the Internet, to ensure that donors are not subject to sanctions or involved in criminal activities. We will also check whether the donor is a Politically Exposed Person (PEP), and if so, we will take additional due diligence measures due to the increased risk of money laundering and terrorist financing.

4.4 Recording and Retention of Information All information collected will be recorded accurately and stored in accordance with privacy and data retention laws. This data will only be used for compliance purposes and will not be disclosed to third parties, except in accordance with applicable laws or at the request of competent authorities.

4.5 Donor risk assessment: Each donor will be assessed on the basis of a risk model that considers various factors, such as the amount of the donation, the country of origin, and whether the donor is on a sanctions or PEP list. This will help determine the level of due diligence required for each donor.

4.6 Procedures for high-risk donations: In the case of donations identified as high-risk, we will adopt additional due diligence procedures, which may include further investigation into the origin of the funds and approval by the Association’s management prior to acceptance of the donation.

The Canadian Chamber in Italy is committed to closely monitoring all donation transactions to identify any suspicious activity that may indicate money laundering or terrorist financing. Effective monitoring of transactions is a key component of our anti-money laundering compliance procedures.

Monitoring Procedure:

5.1 Continuous monitoring: All donation transactions will be subject to continuous monitoring for any warning signs or unusual activity. This includes, but is not limited to, donations of unusually high amounts, repeated transactions in short intervals, or donations from high-risk countries or legal entities.

5.2 Transaction analysis: We will analyse transactions to identify unusual patterns or anomalies. This may include analysis of frequency, amount, source and destination of donations.

5.3 Verification of sources of funds: For transactions of significant amount or in cases where the source of funds is not clear, we will carry out additional verifications to determine the origin of the funds. This activity will include requests for additional information to the donor.

5.4 Suspicious activity checklist: We will develop and maintain a suspicious activity checklist, based on the criteria set out in anti-money laundering laws. This checklist will be used to assess each transaction.

5.6 Escalation Procedures: In the event that suspicious activity is detected, the transaction will be immediately reported to the association’s internal managers for further evaluation and, if necessary, for reporting to the appropriate authorities, in the manner required by applicable regulations.

5.7 Staff training: Staff involved in the donation process will receive regular training on transaction monitoring techniques and the recognition of suspicious activity.

5.8 Data Logging and Retention: All transactions will be recorded and retained for a period of time in accordance with legal requirements. These records will include full details of transactions, including verifications performed and results of analysis.

5.9 Reviewing and updating procedures: Transaction monitoring procedures will be periodically reviewed and updated to ensure that they remain effective and compliant with evolving AML regulations.

The “Canadian Chamber in Italy” recognizes the importance of maintaining its anti-money laundering policy up to date and in compliance with current laws and best practices. Accordingly, we undertake to review and update our policy on a regular basis.

Revision and Updating Procedure:

6.1 Frequency of review: The AML policy will be reviewed at least once a year. However, extraordinary reviews may be convened in response to significant regulatory changes, newly identified threats or vulnerabilities, or as a result of significant internal or external events.

6.2 Responsibility for the review: The task of leading the review of the policy will be entrusted to an internal manager chosen from among the Board members.

6.3 Analysis of regulatory changes and industry practices: An essential part of the review will be the analysis of recent developments in anti-money laundering laws, international regulations, and industry best practices. This will ensure that our policy remains in line with current standards.

6.4 Staff involvement and training: All changes to the policy will be clearly communicated to the Association’s staff and/or volunteers. They will also be trained on any new procedures or aspects of the policy to ensure uniform understanding and implementation.

6.5 Documentation and archiving of revisions: Each policy revision will be documented in detail, including a description of the changes made, the reasons for such changes and the dates on which the revisions take effect. These documents will be archived for tracking and future review purposes.

6.6 Feedback and continuous improvement: During the review process, we will encourage feedback from staff, donors, and other stakeholders to ensure that the policy is practical, effective, and responsive to the needs of the Association.

6.7 Approval of updated policy: Once the review is complete, the updated policy will be submitted to the Association’s Board for approval prior to implementation.

The “Canadian Chamber in Italy” is committed to maintaining accurate and detailed documentation of all donation transactions and donor verification procedures. Record keeping is crucial not only for compliance with anti-money laundering laws, but also to ensure transparency and accountability in our operations.

Record Keeping Procedures:

7.1 Types of records kept: We will keep detailed records including, but not limited to, donor information, copies of verified identification documents, details of donation transactions, results of any sanctions or PEP list checks, and reports of suspicious activity.

7.2 Retention Period: Records will be retained for a period of not less than 10 years, in accordance with Italian anti-money laundering regulations. This period starts from the date of the transaction or the conclusion of the relationship with the donor.

7.3 Data security and protection: Records will be kept securely to protect the confidentiality and integrity of the data. We will take appropriate measures to prevent unauthorised access, loss or accidental destruction of records.

7.4 Compliance with privacy laws: All records retention practices will comply with privacy and data protection laws, ensuring that personal information is handled appropriately and used only for legitimate purposes.

7.5 Access to records: Access to records will be restricted to authorised personnel. Requests for access to records by external authorities, such as law enforcement or regulators, will be handled in accordance with appropriate legal procedures.

7.6 Review of Records: Periodically, records will be internally reviewed to ensure their accuracy, completeness and compliance with established procedures.

7.7 Data Disposal: At the end of the retention period, personal data will be securely disposed of or destroyed in accordance with data protection laws and best practices.