A new Executive Order (EO) signed by President Trump on September 10, 2019, specifically targets correspondent bank relationships as possible sources of terrorist financing. The new order, which gives U.S. Treasury’s Office of Foreign Asset Control (OFAC) the authority to block, prohibit or restrict the scope of these banking relationships, could further limit financial access for nonprofit organizations (NPOs) and other sectors.
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The Charity and Security Network monitors U.S. and foreign government activities and a wide range of news sources to identify developments in national security policy that impact civil society and nonprofit organizations. We collect and disseminate relevant information on our website, via our Twitter and Facebook accounts, and through our biweekly email newsletter, which contains links to a variety of news articles. To read the most recent issues of our email newsletter or to subscribe, click here.
Our staff also creates news pieces on events and developments of particular interest to our members that are not covered in other news outlets. Those stories can be found below, in revese chronological order.
Updated Sept. 24, 2019 Since The Zionist Advocacy Center (TZAC) began using the False Claims Act (FCA) to legally challenge nonprofit organizations (NPOs) working in Palestine only three cases were publicly known. Although TZAC claims it has filed six more cases against NPOs, the identity of the defendants has been a mystery, as FCA cases are automatically sealed when filed for at least 60 days, often longer. Now a federal court has unsealed TZAC’s case against Oxfam GB (Great Britain). The complaint alleges that Oxfam’s Gaza Urban and Peri-Urban Agricultural Platform (GUPAP) provided material support to terrorism, contrary to its anti-terrorism certification to USAID. TZAC argues that because GUPAP allegedly supports ministries tied to both Hamas, which is on the U.S. terrorist list, and the Palestinian Authority (which is not), Oxfam GB’s certification to USAID is false. The U.S. initially declined to exercise its statutory right to take over the case and on Sept. 20 told the court it plans to file a motion to dismiss. Oxfam told the New Humanitarian that “We are aware of the lawsuit and reject the allegation made in it.”
The Charity & Security Network (C&SN), in partnership with the Alliance for Peacebuilding (AfP) and 11 other member organizations, sent a letter to U.S. officials urging defeat of Kenya’s proposal to designate Al-Shabaab a terrorist organization under UN Security Council Resolution 1267, which has no humanitarian safeguards.
On 5 August 2019 the Trump Administration issued an executive order imposing additional sanctions on the Government of Venezuela that specifically allows “transactions related to provision of articles such as food, clothing and medicine intended to be used to relive human suffering.” The next day the Department of Treasury issued a guidance document that
Congressional efforts to update the Bank Secrecy Act could help nonprofit organizations (NPOs) that face increasingly urgent problems with transferring funds across borders. Four Senators have circulated a discussion draft ILLICT CASH ACT that includes provisions to address “bank derisking,” including the impacts on NPOs. A July 11 letter from the Charity & Security Network to Senators Tom Cotton (R-AR), Doug Jones (D-AL), Mike Rounds (R-SD) and Mark Warner (D-VA) expresses support for provisions on derisking and makes recommendations to strengthen them. In particular, the letter urges the bill to require federal banking regulators to update and revise the Bank Examination Manual chapter on NPOs to bring it into line with the Financial Action Task Force’s 2016 update of its standard on anti-terrorist financing regulations for NPOs. The Bank Examination Manual does not incorporate the new standard’s risk-based, proportionate approach that is intended to prevent terrorist financing while not disrupting the activities of legitimate NPOs. (A related bill is awaiting action on the floor of the House of Representatives.)