The architects of the AML/CFT framework deny that de-risking problems are caused by their regulations, "asserting instead that the banks are misinterpreting and/or misapplying the requirements, all the while lamenting the disappearance of clean money into 'shadow banking' channels," write Ben Hayes, Lia Van Broekhoven and Vanja Skoric an Open Democracy article calling on the G20 to take decisive action.
The article, De-risking and non-profits, how do you solve a problem that no-one wants to take responsibility for?, describes several "elephants in the room" around the de-risking of nonprofits. These include the wider problems facing non-profit organizations and a "global system for countering terrorist financing that was quickly drawn-up by US officials in the wake of 9/11 and railroaded through the intergovernmental decision-making system in just six weeks." They also ponder questions "as to the ultimate effectiveness of a system whose 'negative externalities' are piling up, but whose impact in terms of actually stopping the flow of funds to terrorist groups and their supporters is at best disputed and at worst rejected outright."
The article states that non-profits are forced to find workarounds rather than solutions, which further embeds financial institution's practices and argues that time should be taken to find real solutions that benefit all parties.