How does the Agency supervise NPOs?
As the Supervisory Authority for NPOs operating within the Territory, the Agency takes a risk-based approach to its supervision of this sector.
This effectively means that although the Agency supervises all NPOs, not all NPOs will receive the same level of supervision. Resources are therefore proportionate and effective in managing and mitigating the level of money laundering and terrorist financing risk associated with NPOs.
The Agency has a Supervision and Enforcement Unit, which is responsible for supervising NPOs for the purposes of anti- money laundering and countering the financing of terrorism.
They can be contacted at:
Supervision and Enforcement Unit
Email: [email protected]
The supervisory process begins by the Agency gathering information about your NPO. This is done through a risk assessment questionnaire that is completed and sent back to us. The purpose of the questionnaire is to assist the Agency in understanding your NPO, its operations, its size as well as gain an understanding of the types of risk management frameworks that are in place. This helps the Agency to assess the level of risk that the NPO may be exposed to with respect to money laundering and terrorist financing. Therefore, it is important that you complete the questionnaire and provide the Agency with as much information as possible.
Following the risk assessment exercise, if the Agency has any particular concerns or considers that there are high-risk factors, the Agency may ask to review the NPO’s compliance manual. Should the Agency undertake this step, a comprehensive desk-based supervision review of the NPO’s policies, processes and procedures would follow. If any gaps are identified, the Agency would then write to you and explain. The Agency would then work with you in ensuring that the NPO’s compliance manual meets the regulatory requirements.
There will also be instances where the Agency decides to conduct an examination (inspection) of your NPO. Examinations can be offsite (that is we undertake them from our office) or onsite (that is we come to your NPO’s place of business).
Should your NPO be chosen for an examination (either offsite or onsite), the Supervision and Enforcement Unit will contact you to notify you of this examination. You will also be given more information about the examination at this point.
We understand that going through an examination can be a stressful process. Examinations are a usual part of our supervision of NPOs. However, we have devised our processes with this in mind and our aim will always be to ensure that you are kept up to date about what happens.
Should you have any questions about any part of the supervisory process, please feel free to contact the Agency.