Report language in the Omnibus budget bill is intended to rein in the U.S. Agency for International Development’s (USAID) Partner Vetting System (PVS). With the insertion of this paragraph, once the PVS pilot program is completed, USAID and the U.S. Department of State may not implement similar programs unless required to respond to existing security threats. In addition, Congress would have to be consulted before the agencies begin new vetting programs or implement changes to existing programs.
On January 15, 2016, 123 signatories from 46 countries sent a letter calling on the Financial Action Task Force “to open a process to revise Recommendation 8” as it inaccurately states that “Non-profit organisations are particularly vulnerable” to abuse by terrorists. The letter notes that “Recommendation 8 fails to recognize that the vast majority of the millions of NPOs [nonprofit organizations] pursue legitimate charitable activities and that abuse for terrorist financing is rare. Indeed, the FATF Typologies Report, which only identified 102 case studies, acknowledged that cases of abuse are rare.”
A new High Level Review Compendium Report shows a changing attitude towards the effect of UN sanctions on counter-terrorism and humanitarian action. The report indicates a need to redefine and reinforce UN sanctions, as well as a greater concern for the protection of humanitarian work.
The High Level Review (HLR) is a member state-led process supported by academics and consultants specializing in the UN Security Council and sanctions. The process, inaugurated in 2014 and conducted over the course of a year, was sponsored by Australia, Finland, Germany, Greece and Sweden, and has involved consultations with a broad range of member states, UN agencies, sanctions committees, and other stakeholders. The HLR intends to “examine the way sanctions are integrated into the UN’s collective security framework, the relationship between UN sanctions and external institutions and instruments related to peace and security, and emerging challenges,” the report states.
Calling the Financial Action Task Force’s (FATF) standard for government rules to prevent nonprofit organizations (NPOs) from abuse by terrorist organizations outdated, the Global NPO Coalition on FATF submitted proposed revisions to the Interpretive Note (IN) to Recommendation 8 in late November.
For the first time, FATF directed input via a web form that asked for redlined changes to the IN itself and limited general comments to a single page. Because the online format was not conducive to group comments with multiple organizations signing on, the Global Coalition urged individual NPOs to submit their own comments.
In a Nov. 23, 2015 letter to the Department of Treasury, the Charity & Security Network (C&SN)noting the need for “ongoing engagement between the U.S. government and the NPO sector to ensure that measures intended to protect the sector from abuse by terrorist organizations are effective, risk-based, proportionate and not unduly disruptive of the activities of NPOs. “ To achieve this goal C&SN asked that Treasury open the decade-oldAntiterrorist Financing Voluntary Best Practices for NPOsand the Risk Matrix for updating and revision, with input from the nonprofit sector. The letter also asked that Treasury meet with nonprofits to discuss its June 2015 National Terrorist Financing Risk Assessment and ongoing proceedings at the Financial Action Task Force that relate to nonprofits. Treasury responded that it plans to engage the sector on these issues, but provided no details.