For due diligency, what types of questions should we be asking our nongovernmental organization customers? We are a community bank. Our organizations tend to be local charitable groups like Kiwanis or Lions clubs, girl scout troops, and some local accounts opened to assist someone having a recent tragic event, like a house fire or major medical event. Our religious organizations tend to be our local churchs or various church related clubs. Some churches are major congregatons, others might be small groups. To date, we have not found any organization that we consider high risk. We have not found any group doing something suspicious.

There is no one-size fits all to handling customer due diligence and enhanced due diligence. When looking at your NGO's, you should consider the source, type and frequency of their deposits. At account opening, ask what their anticipated activity will be. Monitor to see if there are unusual spikes in activity that you cannot explain. (A spike in deposits by a church at Christmas and Easter can probably be explained by an increase in attendance. A spike in deposits during Girl Scout Cookie season is also easily explainable.) Many NGO's will accept donations or annual dues in cash so this is not uncommon.

You should also ask and monitor to see where the funds are going. If the stated purposed of an NGO is raise money for a sick child, but you start seeing the account signers initiate several wire transfers that are not going to a doctor or hospital, you can start to see some red flags.

Just because an account relationship is in a higher risk class does not automatically make the account high risk. As with due diligence on any account, you have to ask, "How well do I understand the organization and its purpose? and "Does the activity seem justified based on my knowledge of the organization?"

"some local accounts opened to assist someone having a recent tragic event, like a house fire or major medical event."

Unless these have been established as formal charities or trust accounts, these are probably by far your greatest risk.

How are others documenting beneficial ownership of NGOs?

An NGO should not be "owned" so I am a little confused about your question?

Our auditors require additional due diligence on NGOs and subsequently in lieu of beneficial ownership, we need to identify those that have control of the money. How are others accomplishing this? Many of our NGO's don't file IRS form 990.

Who are your auditors and if they require additional information, then they should tell you exactly what they are requiring and not make you guess at it.