Anti-Money Laundering, Counter-Terrorist Financing, Sanctions Compliance and Fraud Prevention Policy

Destek Ol aims to prevent its resources from being used for money laundering, terrorist financing, sanctions violations, fraud, bribery, corruption or the diversion of aid, and to ensure that humanitarian funds are used securely, traceably and for their intended purposes.

Risk-based controls apply to individual and corporate donations, grants, institutional partnerships, local implementing partners, suppliers, service providers, banking and payment transactions, cross-border transfers, in-kind assistance, refunds and other financial or operational transactions.

Know Your Customer (KYC) checks and verification of counterparties’ identity and authority.

Due diligence on partners proportionate to their risk level.

Verification that bank accounts and account holders correspond to the relevant party.

Risk-based screening against applicable sanctions and asset-freezing orders.

Additional documentation, explanations and enhanced review of unusual or suspicious transactions.

Temporary suspension or rejection of transactions, or termination of contracts, to the extent permitted by law.

Controls addressing conflicts of interest, segregation of duties, procurement and fraud prevention.

Retention of transaction and decision records in an auditable form.

Funds and donations must come from legitimate sources.

Another person’s identity or payment instrument must not be used without authorization.

Misleading, false or incomplete identity, organizational or banking information must not be provided.

Third-party accounts, split transactions and misleading descriptions must not be used to circumvent sanctions or legal controls.

Reasonable verification information and documents must be provided when necessary.

The applicable legislation in Türkiye and official asset-freezing and sanctions decisions form the basis of these controls. United Nations sanctions and other foreign sanctions regimes with a legal connection to a transaction are also assessed in light of the relevant bank, currency, country, counterparty, donor or contractual connection. A match against a list does not, on its own, constitute a final determination; identity, ownership, control and the transaction context are verified.

A transaction may undergo additional review where an identity or account mismatch, a request for payment to a personal or unrelated third-party account, unusual cash use, an inconsistent source of funds, split transactions, suspected forged documents, a sanctions match or an unusual transaction pattern is identified. Where necessary, the relevant legal, banking, payment institution or competent authority procedures are followed.

Nationality, religion, ethnicity, displacement status or presence in a conflict area does not, by itself, justify suspicion or rejection. Controls are proportionate to the specific risk, with care taken to avoid unnecessarily obstructing legitimate humanitarian assistance.

Suspected fraud, sanctions violations, bribery, corruption or financial misconduct may be reported to info@destekol.org. Sensitive reports are handled with restricted access under the Complaints and Feedback Policy.