The combating of money laundering and the financing of terrorism has, in recent years, become a challenge of global proportions. Money launderers, terrorists, and criminal groups have become more sophisticated in their methods and techniques. For the purpose of this policy (“the Policy”):

Money Laundering is:
The process by which criminals attempt to conceal the true origin and ownership of the proceeds of criminal activities. If successful, the money can lose its criminal identity and appear legitimate. Criminals do this by disguising the sources, changing the form, or moving the funds to a place where they are less likely to attract attention.

The Financing of Terrorism is:

1) An offense within the meaning of the UN International Convention for the Suppression of the Financing of Terrorism (1999), where a person by any means, directly or indirectly, unlawfully and willingly, provides or collects funds with the the intention that they should be used or in the knowledge that they are to be used, in full or in part, in order to carry out:
(a) An act that constitutes an offense within the scope of and as defined in one of the treaties listed in the annex of the above-mentioned treaty, or

(b) Any other act intended to cause death or serious bodily injury to a civilian, or to any other person not taking an active part in the hostilities in a situation of armed conflict, when the purpose of such act, by its nature or context, is to intimidate a population or compel a government or an international organization to do or to abstain from doing an act.

2) For an act to constitute an offense set forth in paragraph 1, it shall not be necessary that the funds were actually used to carry out an offense referred to in paragraph 1, subparagraph (a) or (b).