NGO's

With the new rules coming into play, I'm sure alot of your banks have charitable foundations. How are you planning on dealing with the new rules for NGO's?

We already cover the items listed on pages 162-163 in our Customer Due Diligence for these types of accounts. Further, they are treated as a special group within our AML monitoring software..

Of course, only our next exam will tell whether that's good enough....

Sorry, I guess I wasn't clear. My bank has it's own Foundation that gives a $1,000,000 to charities that would be considered a NGO. These NGO's do not have accounts at this bank. Although a grant application may say the request the funds for one thing, it could be used for another.

Sorry, you're right, I wasn't looking at it from that perspective. Out of curiosity, does your grant application cover the information you'd expect to collect if the applicant were a customer? Also, do you have the applicant set up an account at the bank, and disburse the funds into the account?

The grant application doesn't come close to the old CIP requirements, let alone the new stuff on NGO's. The funds get disbursed by check at a social gathering to maximize publicity. We receive over 500 apps and give $$$ to 50-75. I'm struggling with the due diligence.

Can someone tell me what new rules you are discussing and where I can locate them? Thanks

Pages 162 and 163 of the new BSA/AML Examination Manual