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May.27, 2010

This morning I had the opportunity to testify before the U.S. House of Representatives Committee on Financial Services Subcommittee on Oversight and Investigations on the topic of "Anti-Money Laundering: Blocking Terrorist Financing and Its Impact on Lawful Charities."

Non-profit organizations are especially susceptible to abuse by terrorists and their supporters for whom charitable or humanitarian organizations are particularly attractive fronts. Here is a selection from my testimony:

The Financial Action Task Force (FATF) – the multilateral body that aims to set global standards for anti-money laundering and counter-terror financing – has found that “Terror networks often use compromised or complicit charities and businesses to support their objectives.” In fact, FATF warned that “the misuse of non-profit organizations for the financing of terrorism is coming to be recognized as a crucial weak point in the global struggle to stop such funding at its source.”

According to the Justice Department, intelligence indicates that terrorists continue to use charities as sources of both financial and logistical support. British officials concur. According to a joint UK Treasury/Home Office report, a “significant proportion” of terror finance investigations in the UK over 2006 included analysis of links to charities. The report found that “the risk of exploitation of charities is a significant aspect of the terrorist finance threat.”

Most charities are completely law-abiding, praiseworthy organizations. But among the minority of charities engaged in supporting terrorism, some are founded with the express purpose of financing terror, while others are infiltrated by terrorist operatives and supporters and co-opted from within. Treasury designations of entire charity tend to focus on the former. Never has the government targeted unwitting donors.

One reason the charitable sector remains vulnerable to terrorist financing according to FATF, is that charities are subjected to lesser regulatory requirements than other entities, such as financial institutions or private companies.

The US has been largely alone in cracking down on abuse of charities and NGOs by Islamist militant groups. Many other countries have been reluctant to take any steps to tackle this problem, often out of concern that they will appear to be targeting Muslim humanitarian efforts.

Despite some criticism, the U.S. government has been consistent in its efforts to protect the donor public and stem the flow of funds to terrorists by cracking down on the abuse of the charitable sector by terrorist organizations. The Treasury Department has designated more than 40 charities with ties to designated terrorist groups, a few with branch offices in the U.S. The U.S. has also prosecuted charities and their leaders, such as in the case of the Holy Land Foundation for Relief and Development (HLF) which was found guilty on all counts in November 2008.

In none of these cases was U.S. government action capricious or based on sparse, dated, or unreliable information. The designation process in particular, I know from first hand experience, is appropriately robust, vigorous and errs on the side of caution. Designated entities can and do appeal their designations, and the Treasury Department has a record of lifting designations when warranted.

It should be clear that charities and international aid organizations come to this problem set from a noble and well intentioned perspective focused on the need to highlight opportunities to facilitate quick, efficient and timely aid. Thankfully, promoting opportunities for charitable giving and reducing the risk those opportunities are abused for illicit purposes are in no way mutually exclusive goals.

Unfortunately, there are those who insist otherwise. They stress that due diligence on the part of charities is difficult and costly, and insist it has only limited value. In fact, the real question of the day is how to most effectively streamline due diligence and make it more cost effective. There should be no debate over the basic threshold for harmonizing charity and security: a basic commitment to non-violence.

Balancing the risk of violence and the opportunity for charity, government and the non-profit sector both have a responsibility to err on the side caution. Both also have a responsibility to work cooperatively to thaw the chilling effect that the government’s public response to terrorists’ abuse of charities has had on charitable giving within the United States, and within Muslim-American communities in particular.

The problem is not enforcement of U.S. laws banning material support to terrorist organizations (indeed, in the history of Treasury’s designation regime only a handful of U.S. based charities have been designated), but rather the unintended impact this has had on charitable giving. Greater due diligence on the part of non-profit organizations, combined with government outreach and information campaigns such as Treasury’s “Updated Anti-Terrorist Financing Guidelines: Voluntary Best Practices for U.S.-Based Charities,” would go a long way toward resolving this problem.