constraints under which each operates and to brainstorm solutions . All stakeholders have a shared interest in facilitating aid where it is needed most . Through robust participation , that goal can become a reality . resources . Consistent with the humanitarian principles of humanity , neutrality , impartiality and independence , humanitarian NGOs are committed to ensuring that aid reaches its intended beneficiaries . These organizations have worked diligently for decades to establish policies and processes that mitigate or prevent — to the maximum extent possible — aid diversion , manipulation and interference from state and non-state actors , including sanctioned or other designated entities .
Their risk management and due diligence systems have been adapted to different contexts in which they operate to address the specific threats they face . These include but are not limited to appropriate beneficiary selection processes , accountability measures , internal and external reporting , monitoring and controls on the use of funds , awareness raising on the risk of terrorist financing , third-party screening , internal audits and investigations mechanisms . Some of the mechanisms implemented by NGOs to prevent the diversion of funds to terrorists or other sanctioned actors include risk management procedures , ethical codes of conduct , incident reporting systems , dedicated policies on counterterrorism measures , screening and vetting procedures , double validation on all purchases and payments , and whistleblowing and complaint mechanisms .
Looking ahead
There is more on the horizon . With the release of its de-risking strategy , the Department of the Treasury hopes to harmonize bank examinations with its policy statements on de-risking , among other changes .
FIs will also have the opportunity to participate in a new round of the U . S . multistakeholder dialogue , set to restart sometime this year . This forum provides an opportunity for all three stakeholder groups — FIs , NGOs and the government — to help each other understand the
As FIs work toward operationalizing the new OFAC general licenses , Phillips-Barrasso notes , “ It is essential that financial service providers see this clear signal and work with humanitarian organizations to ensure that they are able to access the resources needed to run programs , procure goods and pay their staff .”
Andrea Hall , senior manager of the Together Project at InterAction , Washington , D . C ., USA , ahall @ interaction . org
1
“ From Donor to Recipient : A guide to the financial access obstacles facing U . S . nonprofits ,” InterAction , https :// www . interaction . org / wp-content / uploads / 2019 / 03 / Together-Project-Infographic . pdf ; “ The Treasury 2021 Sanctions Review ,” U . S . Department of the Treasury , October 2021 , p . 5 , https :// home . treasury . gov / system / files / 136 / Treasury-2021- sanctions-review . pdf
2
“ Financial Access for U . S . Nonprofits ,” Charity & Security Network , February 2017 , https :// www . charityandsecurity . org / system / files / FinancialAccessFullReport _ 2.21 % 20 ( 2 ). pdf ? msclkid = 875442b7bf2211ecba620abae9820893 ; “ Bank Secrecy Act : Views on Proposals to Improve Banking Access for Entities Transferring Funds to High-Risk Countries ,” GAO , December 2021 , https :// www . gao . gov / assets / gao-22-104792 . pdf ; “ Humanitarian Assistance : USAID Should Improve Information Collection and Communication to Help Mitigate Implementers ’ Banking Challenges ,” GAO , September 2018 , https :// www . gao . gov / assets / gao-18-669 . pdf
3
“ Aid Delivers 2023 : Fundamentals for U . S . Development & Humanitarian Assistance ,” InterAction , https :// www . interaction . org / aid-delivers-2023 / fundamentals-for-u-s-development-humanitarian-assistance /
4
“ Stakeholder Dialogue on De-Risking : Supporting Financial Access for Humanitarian Organizations and Charities ,” World Bank and ACAMS , https :// documents1 . worldbank . org / curated / pt / 538271487141265874 / pdf / 112804-WP-SupportingFina ncialAccessforHumanitarianOrganizationsandCharities-PUBLIC-ABSTRACT-SENT . pdf ; Jacob Kurtzer , Sue Eckert and Sierra Ballard , “ Mitigating Financial Access Challenges ,” CSIS , October 25 , 2022 , https :// www . csis . org / analysis / mitigating-financial-access-challenges
5
“ The Anti-Money Laundering Act of 2020 : Congress Enacts the Most Sweeping AML Legislation Since Passage of the USA PATRIOT Act ,” The National Law Review , January 19 , 2021 , https :// www . natlawreview . com / article / anti-money-laundering-act-2020-congress-enacts-most-sweeping-aml-legislation-passage
6
“ Revocation of the Terrorist Designations of Ansarallah ,” U . S . Department of State , February 12 , 2021 , https :// www . state . gov / revocation-of-the-terrorist-designations-of-ansarallah /
7
“ The Treasury 2021 Sanctions Review ,” U . S . Department of the Treasury , October 2021 , https :// home . treasury . gov / system / files / 136 / Treasury-2021-sanctions-review . pdf
8
“ Financial Access for U . S . Nonprofits ,” Charity & Security Network , February 2017 , https :// charityandsecurity . org / system / files / FinancialAccessFullReport _ 2.21 ( 2 ). pdf
9
“ Bank Secrecy Act : Views on Proposals to Improve Banking Access for Entities Transferring Funds to High-Risk Countries ,” GAO , December 2021 , https :// www . gao . gov / assets / gao-22-104792 . pdf ; “ Humanitarian Assistance : USAID Should Improve Information Collection and Communication to Help Mitigate Implementers ’ Banking Challenges ,” GAO , September 2018 , https :// www . gao . gov / assets / gao-18-669 . pdf
10
“ Stakeholder Dialogue on De-Risking : Supporting Financial Access for Humanitarian Organizations and Charities ,” World Bank and ACAMS , https :// documents1 . worldbank . org / curated / pt / 538271487141265874 / pdf / 112804-WP-SupportingFina ncialAccessforHumanitarianOrganizationsandCharities-PUBLIC-ABSTRACT-SENT . pdf
11
“ Revocation of the Terrorist Designations of Ansarallah ,” U . S . Department of State , February 12 , 2021 , https :// www . state . gov / revocation-of-the-terrorist-designations-of-ansarallah /
12
“ National Security Memorandum on United States Global Leadership to Strengthen the International COVID-19 Response and to Advance Global Health Security and Biological Preparedness ,” The White House , January 21 , 2021 , https :// www . whitehouse . gov / briefing-room / statements-releases / 2021 / 01 / 21 / national-security-directive-unitedstates-global-leadership-to-strengthen-the-international-covid-19-response-and-to-advance-global-health-securityand-biological-preparedness /
13
“ The Treasury 2021 Sanctions Review ,” U . S . Department of the Treasury , October 2021 , p . 5 , https :// home . treasury . gov / system / files / 136 / Treasury-2021-sanctions-review . pdf
14
“ National Security Memorandum on United States Global Leadership to Strengthen the International COVID-19 Response and to Advance Global Health Security and Biological Preparedness ,” The White House , January 21 , 2021 , https :// www . whitehouse . gov / briefing-room / statements-releases / 2021 / 01 / 21 / national-security-directive-unitedstates-global-leadership-to-strengthen-the-international-covid-19-response-and-to-advance-global-health-securityand-biological-preparedness /
15
“ Resolution 2664 ,” U . N . Security Council , December 9 , 2022 , http :// unscr . com / en / resolutions / doc / 2664
16
“ 87 Federal Register 78484 ,” GovInfo , December 21 , 2022 , https :// www . govinfo . gov / content / pkg / FR-2022-12-21 / pdf / 2022-27639 . pdf
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