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Second, this report is focused solely on NPOs. Problems with correspondent banking relationships and MSBs have received significant attention in policy discussions and multilateral fora and have been highlighted in other studies. Difficulties in the correspondent banking and MSB sectors undoubtedly contribute to the current problems NPOs are experiencing. A reduction in correspondent banking relationships makes it more difficult for charities to move money internationally, and MSBs have become an alternative to the formal financial sector. However, the unique obstacles faced by NPOs in accessing financial services remain the exclusive focus of this report. Third, for purposes of this report, NPOs are defined according to the IRS’s definition of charitable activity, 16 which includes major humanitarian aid organizations, human rights groups and funds, friendship societies, faith-based organizations, environmental groups, museums, hospitals and universities. These organizations provide direct services (such as Save the Children or Doctors Without Borders) and conduct advocacy (such as the ACLU or Amnesty International). Foundations, including public grantmaking organizations (such as community foundations or Global Fund for Women) and private grantmaking organizations (such as the Ford Foundation), are also included in the scope of NPOs. The broad charity and foundation community is therefore included under the term NPOs. It should be noted that “NPOs” and “charities” are used interchangeably throughout this report. Finally, the information and data presented in this report are intended to help facilitate an informed dialogue with regulators, policymakers, the financial community and the broader public. The report does not purport to be definitive in its assessments, but rather provides the first empirical information upon which informed discussion of solutions, as well as additional research, can be based. While further analysis will be useful in understanding the issues with finer granularity, the evidence presented in this report underscores the immediacy of the problem and the need to address these issues now. For the first time, we now know the scope and nature of the difficulties American nonprofits are experiencing with financial access, as well as some of the consequences of these problems. The work of nonprofits benefits broad foreign policy and security objectives, and this report should be read as a call to action for all stakeholders to reassess policies and work together to more effectively promote the multiplicity of U.S. interests. 16 A 501(c)(3) organization, also colloquially known as a 501c3, is a United States nonprofit organization that has been approved by the Internal Revenue Service to be tax-exempt if its activities have the following purposes: charitable, religious, educational, scientific, literary, testing for public safety, fostering amateur sports competition, or preventing cruelty to children or animals. See IRS, Exempt Purposes - Internal Revenue Code Section 501(c)(3), https://www.irs.gov/charities-non-profits/charitable-organizations/ exempt-purposes-internal-revenue-code-section-501c3. INTRODUCTION 5
SECTION ONE BACKGROUND Chapter 1 METHODOLOGY This study was undertaken as an investigation aimed at assessing the scope and nature of financial problems experienced by nonprofit organizations that work in foreign countries. Rather than test a hypothesis, the research was designed to discover the basic information necessary for stakeholders in the government, financial and nonprofit sectors to engage in constructive future dialogue and action. This approach required the production of empirically sound data as well as information from focus groups, stakeholder interviews and desk research. This chapter describes the methodology used. Systematic Random Sample of Defined U.S. NPOs The Charity & Security Network commissioned the Schar School of Policy and Government at George Mason University (GMU) to design a survey of U.S.-based NPOs that conduct work in foreign countries in order to produce reliable and valid data to be combined with more qualitative information. Professors Delton T. Daigle and Stefan Toepler led the survey team. 17 The study defined “nonprofit organizations” by utilizing the IRS definition for organizations claiming tax-exempt status as public charities under Section 501(c)(3) of the Internal Revenue Code. According to the IRS, exempt purposes are: “Charitable, religious, educational, scientific, literary, testing for public safety, fostering national or international amateur sports competition, and preventing cruelty to children or animals. The term charitable is used in its generally accepted legal sense and includes relief of the poor, the distressed, or the underprivileged; advancement of religion; advancement of education or science; erecting or maintaining public buildings, monuments, or works; lessening the burdens of government; lessening neighborhood tensions; eliminating prejudice and discrimination; defending human and civil rights secured by law; and combating community deterioration and juvenile delinquency.” 18 17 The data used in this report will be made publicly available in the coming months. Contact the Charity & Security Network to obtain the data. 18 IRS, Exempt Purposes - Internal Revenue Code Section 501(c)(3), www.irs.gov/charities-non-profits/charitable-organizations/ exempt-purposes-internal-revenue-code-section-501c3. SECTION ONE: BACKGROUND 6
Page 1 and 2: FINANCIAL ACCESS for U.S. NONPROFIT
Page 3 and 4: ABOUT THE CHARITY AND SECURITY NETW
Page 6 and 7: List of Figures and Tables Figures
Page 8 and 9: Acknowledgements The study benefite
Page 10 and 11: EXECUTIVE SUMMARY In response to th
Page 12 and 13: The scope of the problem, which aff
Page 14 and 15: The U.S. government process to addr
Page 16 and 17: Improve Implementation of the Risk-
Page 18 and 19: INTRODUCTION On September 8, 2000,
Page 20 and 21: have delayed or denied financial tr
Page 24 and 25: Most NPOs that claim tax-exempt sta
Page 26 and 27: Chapter 2 THE CONTEXT FOR NPO FINAN
Page 28 and 29: The Risk-Based Approach Although th
Page 30 and 31: FATF TREATMENT OF NPOs 38 In Octobe
Page 32 and 33: in compliance activities. Extensive
Page 34 and 35: Regulatory Authorities for Financia
Page 36 and 37: NPOs AND DUE DILIGENCE Robust due-d
Page 38 and 39: As was previously mentioned, obtain
Page 40 and 41: Chapter 3 DERISKING: COMPLICATIONS
Page 42 and 43: While FIs do not discuss issues rel
Page 44 and 45: Geographic Derisking Derisking also
Page 46 and 47: Security Consequences of Derisking
Page 48 and 49: account or electronic instrument to
Page 50 and 51: “…it is not surprising that som
Page 52 and 53: to the entire sector as “high-ris
Page 54 and 55: There are 8,665 such groups, based
Page 56 and 57: Table 4: Frequency of Financial Acc
Page 58 and 59: NPOs Are Paying Higher Fees for Ban
Page 60 and 61: Wire Transfers Destined for All Par
Page 62 and 63: Figure 9: U.S. Government Funding b
Page 64 and 65: An insufficient number of survey re
Page 66 and 67: Turn the proportions of NPOs servin
Page 68 and 69: SECTION THREE PERSPECTIVES OF PRIMA
Page 70 and 71: The undertone of skepticism as to w
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Moreover, U.S. government officials
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Acknowledgement of Derisking and Re
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Engagement with NPO Sector As NPOs
Page 78 and 79:
Some interviewees commented that th
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was designed as a regime to help la
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Numerous FIs emphasized that, “Th
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Response to U.S. Government Efforts
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Several FIs shared their suggestion
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NPOs also consistently complain abo
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Chapter 7 NONPROFIT ORGANIZATIONS "
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NPOs Support AML/CFT Policies but A
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Unfamiliarity with NPO Business Mod
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Table 9: Transparency Standards and
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Delays in Fund Transfers Some NPOs
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Excessive Information Requests Info
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Problems Opening Foreign Accounts W
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workarounds to problems of access t
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The Thomson Reuters Foundation cond
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SECTION FOUR OBSERVATIONS & RECOMME
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Implementation of the Risk-Based Ap
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The U.S. government process to addr
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RECOMMENDATIONS Launch a Solutions-
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NGO SOURCE: A MODEL THAT COULD BE A
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Improve Implementation of the Risk-
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Other Options In cases in which for
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• Further research should examine
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APPENDIX A BIBLIOGRAPHY Books • E
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• Long, Paige. “Banks say take-
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• FATF. “Best Practices Paper:
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The Urban Institute Center on Nonpr
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• Financial Crimes Enforcement Ne
Page 134 and 135:
Web Resources • Charity & Securit
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Given the difficulty [your organiza
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34. Can you estimate for us the num
Page 140:
South Asia Afghanistan, Bangladesh,
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