Compliance for Non-Profit Organizations

In today’s global marketplace, operating a charitable organization is extremely competitive and can be fraught with risk. U.S. charities have an obligation under Executive Order 13224 to demonstrate that any foreign recipient organization to which they donate does not appear on any terrorist or money laundering list of the U.S. Government, including the Department of the Treasury’s OFAC Specially Designated Nationals List (SDN).

The charity should require the foreign recipient organization to undertake reasonable steps to ensure that funds provided by the charity are not ultimately distributed to terrorist organizations. In addition, the charity should determine that the foreign recipient organization is banked by a reputable bank not involved in money laundering or from an area that lacks adequate anti-money laundering controls.

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