Anti-Money Laundering

 

Policy Summary

It is the policy of the George Washington University to comply with anti-money laundering obligations imposed by the federal government and the rules and regulations overseen by the United States Treasury Department’s Office of Foreign Assets Control and Financial Crimes Enforcement Network, and other legal requirements. 

Related Regulations

The Money Laundering Control Act of 1986, the Bank Secrecy Act, and the USA PATRIOT Act of 2001. 

Who is Governed by this Policy 

  • Students
  • Staff
  • Faculty

Policy

To assist the federal government in detecting, preventing, and eradicating criminal and terrorist financing and activity, the university will take all necessary steps to comply with applicable anti-money laundering laws and regulations.   

The university will maintain an anti-money laundering program in accordance with the Bank Secrecy Act, as amended by the USA PATRIOT Act, and other applicable federal laws and regulations. The program is reasonably designed to prevent university services from being used to facilitate money laundering and the financing of terrorist activities.  The program includes the following: 

A. Procedures to verify customer identification and retain necessary identifying and transactional information; 

B. A designated compliance officer to coordinate compliance with the program; 

C. Suspicious activity reporting procedures and document retention guidelines for any suspicious activity reports and supporting documentation; and 

D. Training and education of appropriate university personnel concerning their responsibilities under the program, including suspicious activity reporting. 

Concerns regarding transactions that are unusually large or that appear suspicious and questions regarding money laundering in general should be directed to the university’s Treasury Management Office.  

Definitions

Money laundering is conducting or attempting to conduct a financial transaction knowing that the transaction is designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of specified unlawful activity.  

Related Information

31 C.F.R. Part 1010, 1022  

31 U.S.C. § 5311, et seq.

A Brief Primer on Doing Business Abroad: U.S. Laws that Affect GW’s International Activities 

Bank Secrecy Act, 12 U.S.C. §1951, et seq.

Compliance with Law when Conducting University Activities Overseas 

Money Laundering Control Act of 1986, Public Law 99-570 

USA PATRIOT Act of 2001, Public Law 107-5 

Contacts

Contact Phone Number Email Address
Treasury Management 571-553-4156  [email protected]
Senior Vice President and General Counsel  202-994-6503  [email protected]

Responsible University Official: Assistant Director, Cash and Debt Management
Responsible Office: Treasury Management

Last Reviewed: November 20, 2019

 

Non-compliance with this policy can be reported through this website.