Tender Description

TERMS OF REFERENCE (ToR) FOR CONSULTANCY
Title: Consultant for Development of anti-money laundering (AML) and counter-terrorism 
financing (CTF) policy
Organization: GREDO Non-Profit Organization
Location: Mogadishu/Baidao
Duration: 2 week
I. Background:
GREDO Non-Profit is a dedicated organization committed to Gargaar Relief Development 
Organization (GREDO) is a local non-profit, non governmental humanitarian and 
development organization with its Headquarters in Baidoa and have sub-oces across south 
central Somalia initiated in December 1992 by a group of Somali intellectuals and well 
wishers responding to a need. GREDO focuses on aspects of emergency, humanitarian 
responses and development/resilience programmes. To enhance our operational efficiency 
and financial accountability.
GREDO seeks the services for development of an anti-money laundering (AML) and counterterrorism financing (CTF) policy for GREDO:
The development of a robust AML/CTF policy tailored to GREDO’s specific needs and 
operations in Somalia, will help to prevent financial crime and safeguard its mission and 
reputation.
1. Objective:
 * Develop a comprehensive AML/CTF policy to ensure compliance with international and 
national standards and regulations, mitigate financial crime risks, and safeguard the 
organization's reputation and integrity.
2. Scope:
 * Define the scope of the policy, including its applicability to all activities, programs, and 
operations conducted by GREDO within Somalia.
 * Specify the types of transactions, funds, and activities covered by the policy, including 
donations, grants, remittances, and partnerships.
3. Methodology:
 * Adopt a risk-based approach to assess and mitigate AML/CTF risks associated with 
GREDO's operations, focusing on identifying and prioritizing high-risk areas and 
vulnerabilities.
 * Establish procedures for conducting due diligence on donors, partners, vendors, 
beneficiaries, inters, volunteers and other stakeholders to mitigate the risk of illicit financing 
and ensure compliance with regulatory requirements.
4. Responsibilities:
 * Define the roles and responsibilities of staff members, management, and the board of 
directors in implementing and enforcing the AML/CTF policy.
 * Assign accountability for monitoring transactions, identifying suspicious activities, and 
reporting potential AML/CTF concerns to relevant authorities.
5. Timelines:
 * Establish a timeline for the development, approval, and implementation of the AML/CTF 
policy, including key milestones and deadlines for completion.
 * Schedule regular reviews and updates of the policy to ensure its effectiveness and 
relevance in addressing evolving AML/CTF risks.
6. Regulatory Compliance:
 * Ensure compliance with relevant national laws, regulations, and international standards, 
including those set forth by the Financial Action Task Force (FATF), The National Anti-Money 
Laundering and Countering the Financing of Terrorism Committee (NAMLC) chaired by the 
Minister of Finance and includes the Ministers of Justice, National Security, Commerce & 
Industry, and the Governor of the Central Bank, the Attorney General, the Director of the 
National Intelligence and other regulatory bodies.
 * Stay informed about changes in AML/CTF regulations and incorporate updates into the 
policy as necessary.
7. Risk Assessment:
 * Conduct a thorough risk assessment to identify and evaluate AML/CTF risks associated 
with GREDO's activities, stakeholders, and geographical locations.
 * Develop risk mitigation strategies and controls to address identified risks and 
vulnerabilities effectively.
8. Detection Mechanisms:
 * Implement robust systems and procedures for detecting and monitoring suspicious 
transactions, including transaction monitoring tools, red flags indicators, and anomaly 
detection techniques.
 * Establish protocols for investigating and escalating suspicious activities internally and 
reporting them to relevant authorities as required.
9. Reporting Protocols:
 * Define procedures for documenting and reporting suspicious transactions, including the 
submission of suspicious activity reports (SARs) to the Financial Reporting Center (FRC), The 
National Anti-Money Laundering and Countering the Financing of Terrorism Committee 
(NAMLC) or other designated authorities.
 * Ensure that reporting protocols comply with confidentiality requirements and data 
protection regulations.
10. Training and Awareness:
 * Develop training programs and materials to raise awareness among GREDO staff, 
volunteers, and partners about AML/CTF risks, policies, and procedures.
 * Provide regular training sessions and updates to ensure that all stakeholders understand 
their roles and responsibilities in combating financial crime.
11. Monitoring and Evaluation:
 * Establish mechanisms for ongoing monitoring and evaluation of the effectiveness of the 
AML/CTF policy, including regular audits, reviews, and assessments.
 * Conduct periodic reviews of GREDO's AML/CTF controls, processes, and procedures to 
identify areas for improvement and address emerging risks.
12. Confidentiality and Data Security:
 * Implement safeguards to protect sensitive financial information and personal data 
collected during the course of GREDO's activities.
 * Ensure compliance with data protection laws and regulations by establishing data 
security measures, access controls, and confidentiality agreements.
IV. Deliverables:
The consultant is expected to deliver the following:
▪ AML/CTF policy and procedures.
▪ A detailed proposal for revisions and improvements to AML/CTF policy and 
procedures.
▪ Training program, materials and documentation for GREDO Board, Staff, Interns, 
Volunteers, Vendors & other stakeholders .
▪ Mechanisms for ongoing monitoring and evaluation of the effectiveness of the 
AML/CTF policy,
▪ Reporting protocols comply with confidentiality requirements and data protection 
regulations

Skills Required

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