In the wake of the ongoing pandemic, various charities have been created with mission statements specific to COVID-19. What seems like an opportunity for giving back may present yet another vehicle for fraud to money launderers and other fraudsters.

To try to help weed out the legitimate from the not so innocent, on November 19, 2020, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a press release announcing a joint fact sheet (Fact Sheet), prepared in coordination with Federal Banking Agencies (defined below), “to provide clarity to banks on how to apply a risk-based approach to charities and other non-profit organizations (NPOs).” The press release and Fact Sheet seek to strike a balance between recognizing “the important role played by the charitable sector, especially during the COVID-19 pandemic” while reminding financial institutions to utilize the risk-based approach when conducting due diligence and developing risk profiles for charities and other NPOs.

This not the first time that the Treasury Department has raised concerns about charities, albeit in a different context: according to the Treasury Department’s reports on the 2020 National Strategy for Combatting Terrorist and other Illicit Financing and the 2018 National Terrorist Financing Risk Assessment, some charities and non-profit organizations (NPOs) “have been misused to facilitate terrorist financing.” And it is certainly not the first time that FinCEN has raised concerns about specific types of fraud fueled by the global pandemic (see here, here and here).
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