If I were to go to that extent, then I'd treat it similarly to CDD/EDD on any other party. I'd have the NGO provide the "large contributors" list and any due diligence they've conducted, then I'd do additional verification/research (OFAC, PEP lists, negative news) on the list. The end product would be a document detailing this. For example:
Last edited by Hovis; 02/10/11 02:32 AM.
Sam Slade - Slade, CEO of Ripov Oil Corp, personally donated $3.5 million to the Endangered Children Foundation in 2010. Negative news, OFAC, and PEP list searches yielded no derogatory information on Slade.
XYZ Corp - XYZ Corp, an electron tube manufacturer, donated $1 million to the Endangered Children Foundation in 2010. Negative news and OFAC list searches yielded no derogatory information on XYZ Corp.
I know of no guidance suggesting it should be done exactly as above; however, a run-of-the-mill due diligence document should be suffice.
But, as Ken suggested, most NGOs aren't high risk. Performing everything suggested in the manual is excessive for the vast majority of NGOs. Be careful not to handcuff yourself to an "overkill" process.