ITTO ANTI-MONEY LAUNDERING AND COUNTERTERRORISM FINANCING POLICY (AML/CFT)

Revised in November 2018

INTERNATIONAL TROPICAL TIMBER ORGANIZATION

Adopted by the International Tropical Timber Council through Decision 3(LIV)ITTO ANTI-MONEY LAUNDERING AND COUNTER TERRORISM FINANCING POLICY (AML/CFT)Table of Contents
I.
Introduction
II.
High-level AML/CFT declaration and linkages with other documents
III.
High-level decisions to setup AML/CFT system and strategic objectives
IV.
Content of AML/CFT Program
I.

Introduction

The maintenance of sustainable forest management is based on a good regulatory framework. Today theglobal efforts to prevent money laundering and to counter terrorism financing are essential to protect thesustainable management and the integrity of financial system.
International Tropical Timber Organization (ITTO) is committed to the highest standards of anti-money
laundering and counter terrorism financing (AML/CFT). ITTO requires its management and staff, and theexecutive agencies to adhere to these standards to protect ITTO and its reputation from being misused formoney laundering and/or terrorism financing or other illegal purposes.
ITTO incorporates in its activity the international standards that are established by the Financial Action TaskForce (FATF), which is recognized as the international standard setter for AML/CFT efforts. The objectives ofthe FATF are to set global standards and promote effective implementation of legal, regulatory and operational
measures for preventing money laundering and terrorism financing, and other related threats to the integrityof the international financial system.
ITTO examines its strategies, goals and objectives on an ongoing basis and maintains an effective program
for the forest management, which reflects the best AML/CFT practices. ITTO recognizes that increasing thetransparency of its projects can also help to reduce illegal timber activities.
II.

High-level AML/CFT declaration and linkages with other documents

AML/CFT standards, developed by FATF, are integrated into the whole financial system as well as into theprivate sector activities. In June 2015 FATF stressed and raised the understanding of the importance andpurpose of FATF standards being integrated with private sector including emerging economies and low incomecountries.
ITTO AML/CFT program undertakes to supplement a good forest governance clearly understanding themoney laundering and terrorism financing risks, and adapting its system to the nature of these risks.
ITTO incorporates AML/CFT policy and program in operational activities bringing risks assessment andmitigation measures in compliance with the FATF Recommendations. AML/CFT is being understood as theprevention of money laundering and terrorism financing or other relevant crimes.
The AML/CFT Program assists ITTO professional staff, the executive agencies and partners to prevent moneylaundering and terrorism financing and to propose ways to mitigate the risks.
The procedures of adequate AML/CFT control in the operational activity of ITTO are being understood as theset of established appropriate AML/CFT basic concepts and procedures, and due diligence measuresaccording to the FATF standards.
An integration of new AML/CFT measures with the existing ITTO due diligence controls incorporates suchactions as adequate and strict identification and verification requirements (“Know Your Customer”, KYC),
record keeping of on-going transactions and relations, screening and monitoring procedures, risk assessment
and risk-based approach, simplified and enhanced due diligence measures, and regular review of all existing
business relationships.
ITTO designs the procedure for applying actions in case of suspicious activity detection. ITTO undertakes toconduct training of its staff for AML/CFT and to incorporate an audit of AML/CFT function into ITTO audit
procedures.

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The ITTO AML/CFT program should be implemented globally and throughout all business operations.
The ITTO AML/CFT program protects the integrity and stability of ITTO by establishing the preventive
component as the first barrier against the commission of acts of money laundering and the financing ofterrorism.
This document has linkages with the following main documents:a)
b)
c)
d)e)
f)g)
h)i)
j)
III.

International Standards on Combating Money Laundering and the Financing of Terrorism &Proliferation - the FATF Recommendations – 16 February 2012;
Improving Global AML/CFT Compliance: on-going process – 26 June 2015;
FATF Guidance: Politically Exposed Persons (Recommendations 12 and 22);
Guidance on Transparency and Beneficial Ownership;
National money laundering and terrorist financing risk assessment;
Best Practices Paper: The Use of the FATF Recommendations to Combat Corruption;
FATF Guidance on Anti-Money Laundering and Terrorist Financing Measures and Financial
Inclusion and its update;
FATF Guidance: The Implementation of Financial Provisions of United Nations Security Council
Resolutions to Counter the Proliferation of Weapons of Mass Destruction;
FATF Report: Risk of Terrorist Abuse in Non-Profit Organizations;
FATF response to the public consultation on the revision of the FATF Recommendation.
High-level decisions to setup AML/CFT system and strategic objectives

With the purpose of making a significant contribution to the global efforts towards preventing money launderingand terrorism financing and of minimizing the reputation risks of unwilling association with money launderingand terrorist financing, the International Tropical Timber Council (ITTC) approves the ITTO AML/CFT Policy.
The requirements of FATF should be integrated into the ITTO AML/CFT day-to-day activities.
By adopting a risk-based approach, ITTO ensures that measures to prevent or mitigate money laundering andterrorist financing are commensurate with the risks identified. Based on risk assessment, ITTO will allocate its
own resources in the most effective way to prevent money laundering and terrorism financing.
According to its AML/CFT Program, ITTO incorporates the mechanism to identify, assess, monitor, manage
and mitigate money laundering and terrorist financing risks. ITTO takes enhanced measures to manage andmitigate the higher risks and in case of lower risks, simplified measures may be permitted.
The Program reflects the nature of ITTO business, its relations with executive agencies and other partners,
existing AML/CFT capacities and requirements for the AML/CFT system. The AML/CFT Program shall beapproved by the Executive Director of ITTO and reviewed annually. The AML/CFT report will be an integral
part of ITTO annual report. The ITTO staff is required to act in compliance with the AML/CFT Program.
The Executive Director has a vital position in ensuring that AML/CFT controls work effectively in ITTO and has
authority to deny new relations with partner or to terminate the existing ones in case of any non-compliancewith AML/CFT requirements.
The Executive Director designates a Compliance Officer to be responsible for AML/CFT function, namely
providing advice, drafting policies and monitoring assurance/oversight including a postponement of suspicioustransactions. The Compliance Officer exercises such other functions as may be appropriate to fulfil theobjectives of the ITTO. The Compliance Officer undertakes to report to the Executive Director, in case ofnecessity, directly, and to the ITTC annually.
The Compliance Officer is responsible for ITTO’s adherence to applicable AML/CFT standards and assists
the executive agencies and partners to follow such policies. In addition, the Compliance Officer is responsiblefor establishing and maintaining ITTO AML/CFT training of its staff and supporting robust country coordination
with regard to the identification, assessing, monitoring and managing risks related to money laundering,terrorist financing and predicate offences.

2The Compliance Officer acts as a focal point for ITTO AML/CFT activities and cooperates, in case of necessity,with relevant national authorities through the country focal points. The Compliance Officer has a level ofauthority and independence within the ITTO and access to resources and information sufficient to carry out
AML/CFT duties.
IV.

Content of AML/CFT Program

The content of AML/CFT Program shall include the following:
1. AML/CFT Basic Concepts
2. Money laundering and terrorism financing risks applicable to ITTO and their mitigation
3. AML/CFT Procedures
4. Due Diligence Measures
5. Actions in Case of Suspicious Activity Detection
6. ITTO Training for AML/CFT
7. Audit of AML/CFT Function
Annexes**

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