Following a significant delay in the update of the nonprofit organization (NPO) sections of the Federal Financial Institutions Examination Council’s (FFEIC) Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (Manual), and in light of the urgent need to send program funds abroad to address the Covid-19 crisis, Charity & Security Network has published an open letter to the FFIEC. The letter asks the group to issue an urgent update to the Manual and to virtually train examiners on the update and application of the risk-based approach.
The letter states, in part, “Three years after the publication of our empirical study, Financial Access for U.S. Nonprofits, nonprofit organizations (NPOs) continue to struggle to maintain bank accounts and send program funds abroad in a timely manner. The continuing difficulties with financial access mean that NPOs cannot prevent, mitigate and respond to conflict, disaster and disease quickly enough. Today, it is hindering the rapid response demanded by situations such as Covid-19.”
Following the publication our 2017 empirical study, Financial Access for U.S. Nonprofits, a group of NPOs and banks met under the auspices of the World Bank/ACAMS multi-stakeholder dialogue to draft suggested changes to the NPO sections of the Manual. Those revisions were submitted to the FFIEC in October 2017. Although the FFIEC published a partial update to the Manual on April 15, those changes are not yet reflected in the NPO sections of the Manual.