The Don Ugbo Health Empowerment Foundation (DUHEF) recognizes the critical importance of preventing money laundering and terrorism financing. We are fully committed to maintaining the highest standards of Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) within the Federal Republic of Nigeria.
As a Designated Non-Financial Business and Profession (DNFBP) under Nigerian law, DUHEF is strictly subject to applicable statutory frameworks designed to prevent financial crimes. This policy is built in strict compliance with:
The Money Laundering (Prevention and Prohibition) Act, 2022
The Terrorism (Prevention and Prohibition) Act, 2022
Regulations issued by the Special Control Unit Against Money Laundering (SCUML) under the Economic and Financial Crimes Commission (EFCC).
To fulfill this commitment, DUHEF has established comprehensive internal controls. This Policy outlines the mandatory standards that every employee, volunteer, board member, and institutional partner of DUHEF must observe.
Money Laundering (ML): The process or activity by which criminally obtained money or assets (criminal property) are processed or integrated into legitimate channels so that they appear to come from a clean, legal source.
Terrorism Financing (TF): The provision, collection, distribution, or management of funds (directly or indirectly) with the intention or knowledge that they will be used, in full or in part, to execute terrorist acts or support terrorist organizations.
This Policy applies to all operations, grants, corporate sponsorships, and individual donations received or managed by DUHEF. It aims to ensure the foundation’s platform is never exploited for illicit financial gains or terrorist facilitation.
To prevent the integration of illicit funds, DUHEF implements strict Know Your Donor (KYD) and Know Your Partner (KYP) verification procedures through our Partner Screening Framework. We identify and verify the identity of our stakeholders using:
Official, government-issued identification and registration documentation (Verification Checking).
Independent validation of organizational ownership and corporate structures for institutional grantors (Ownership/Control Checking).
Mandatory alignment with DUHEF’s Ethical Code of Conduct.
Note: Any unusual, evasive, or suspicious behavior observed during the due diligence process must be reported immediately to the DUHEF Anti-Money Laundering Reporting Officer (AMLO).
DUHEF applies a risk-based approach to assessing incoming funding streams. The level of scrutiny depends heavily on the geographic location of the donor, the structure of the donating entity, and the volume of the donation. Identifying potential risk tiers allows the foundation to deploy tighter verification controls where exposure is highest (e.g., anonymous high-value donations or cross-border grants from unverified jurisdictions).
DUHEF will strictly refuse to accept donations from, or partner with, individuals or entities that fall into the following categories:
Persons or entities listed on official national or international sanctions lists (e.g., United Nations, Nigerian federal sanctions lists).
Individuals indicating clear or high-probability involvement in criminal or subversive activities.
Donors whose source of wealth or legitimacy of funds cannot be reasonably verified.
Entities or individuals who explicitly refuse to provide mandatory identification or regulatory documentation.
Corporate or institutional entities whose ultimate beneficial ownership or shareholder control structure is intentionally obscured.
All physical and electronic records concerning donor identification, transaction histories, screening questionnaires, and verification steps are stored securely.
In compliance with Nigerian law, all records must be retained for at least five (5) years following the conclusion of the relationship or transaction.
DUHEF shall designate a qualified compliance officer to serve as the Anti-Money Laundering Reporting Officer (AMLO). The AMLO holds operational responsibility for:
Reviewing internal reports of suspected money laundering or terrorism financing.
Actively filing statutory reports to relevant authorities, including weekly or threshold reports to SCUML.
Serving as the primary liaison between DUHEF and national financial intelligence or law enforcement authorities.
Conducting mandatory AML/CFT training programs for staff, management, and volunteers.
Designing, updating, and monitoring internal compliance procedures.
If any employee, volunteer, or contractor becomes aware of facts, trends, or behaviors that trigger a suspicion of money laundering or terrorist financing, they must report it to the AMLO without undue delay.
An internal Suspicious Activity Report (SAR) must securely detail:
The identity of the person raising the concern and the date of the report.
The name and details of the individual or entity under suspicion.
The specific facts, transaction patterns, or behaviors prompting the suspicion.
The potential impact or involvement of DUHEF’s accounts or programs.
The AMLO will evaluate the internal report objectively. If the suspicion is deemed credible, the AMLO will file an official report to the regulatory authorities. All internal compliance reports are held separately from public donor files to ensure total confidentiality and prevent “tipping off.”
DUHEF maintains a zero-tolerance stance on non-compliance. All permanent staff and key operational contractors must complete mandatory AML/CFT compliance training on an annual basis. Specialized training is provided to personnel managing accounts, grants, and donor relations to ensure they can identify red flags, handle high-value compliance workflows, and properly escalate suspicious activity.
This Policy is subject to regular reviews to match evolving Nigerian statutory frameworks. Periodic compliance audits will be executed by DUHEF’s internal audit function, providing Executive Management and the Board of Trustees with objective assurance regarding the operational effectiveness of the foundation’s financial safeguards.
Signed:
Executive Management & Board of Trustees
Don Ugbo Health Empowerment Foundation (DUHEF)
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