Sanctions, counter-terrorism financing and due diligence policy

1. Commitments

• TIPCS will not knowingly receive, hold, move or give funds that come from, or are meant for, terrorism, money laundering, organised crime or any person or body on a sanctions list that binds it.
• TIPCS stays independent and nonpartisan. It does not raise funds for, or give material support to, any political party or candidate, and does not accept funds from states without diplomatic relations with Tunisia, or from bodies that defend them, or funds that would compromise its independence or the law.
• Protecting humanitarian and peace work: these rules are applied in proportion to risk and are not used to avoid legitimate work with communities, victims or at-risk groups.

2. Donors and funds received

• Before accepting a gift or grant above 1,000 TND (or lower for a new or unusual source), TIPCS asks who the donor is, checks the name against UN, EU, US (OFAC), UK and national sanctions lists, and records the check. Any red flag (hidden identity, conditions that restrict independence, cash, third-party payers, round-tripping, unusual size) is raised with the Secretary General before acceptance.
• Funds are received only into the TIPCS bank or post-office account, by bank transfer; no cash, no anonymous or crypto-asset gifts.
• Foreign funding is declared in the register on the Funding and transparency page and notified to the Secretary General of the Government within one month, as Article 41 of Decree-Law 2011-88 requires. Principal funders and the share each provides are disclosed yearly.
• Grant agreements are read for clauses on sanctions, audit, publicity, data and independence before signature, and TIPCS declines terms it cannot lawfully or ethically meet.

3. Partners, suppliers, staff and participants

Before signing with a partner, sub-grantee, consultant or major supplier, TIPCS checks identity, legal registration, beneficial owners where known, reputation, and the sanctions lists, repeating the check each year and when the relationship changes. Contracts oblige them to comply with applicable law and sanctions, to tell us of any listing or investigation, and allow us to suspend and recover funds. Payments go only to accounts in the name of the contracting party. Participants in public events are not screened, but TIPCS does not pay or provide material support to listed persons.

4. Money-laundering controls

TIPCS uses regulated banks, keeps records of donors, grantees and payments for ten years, watches for unusual transactions, and reports suspicion without delay to the Tunisian Financial Analysis Commission (CTAF) through its bank or directly, without alerting the person concerned. The bank’s own reporting duties (including inbound transfers to associations) are respected and cooperated with.

5. Personal data and proportionality

Screening data are used only for these checks, kept as long as the law and donor agreements require, and protected under the Privacy policy and Organic Law No. 2004-63. TIPCS collects the minimum needed.

6. Reporting and governance

Staff must report any suspicion at once through the Whistleblowing and complaints policy. The Treasurer keeps the due-diligence register; the Secretary General approves or refuses doubtful funds and informs the Board, which reviews this policy and a summary of checks every year.