Anti-Fraud, Anti-Bribery & AML Policy

Last updated: November 11, 2026

Policy statement

Emerge Epicenter Foundation has zero tolerance for fraud, bribery, corruption, money laundering and terrorist financing. We comply with applicable laws in the United States and Nigeria, including Nigeria’s Money Laundering (Prevention and Prohibition) Act and SCUML requirements for non-profit organisations.

Controls

• Dual authorisation for payments and bank transfers.
• Segregation of duties between those who approve, record and reconcile transactions.
• Due diligence on partners, suppliers and significant donors.
• Large or unusual donations are reviewed before acceptance.
• Screening against government sanctions lists where required.

Gifts and hospitality

Staff and volunteers may not offer or accept bribes, facilitation payments or gifts intended to influence decisions.

Reporting

Suspected fraud or financial misconduct must be reported under our Whistleblower Policy. We will investigate, take disciplinary or legal action where appropriate, and report to authorities as required.