Heading to The Hill: Engaging U.S. policymakers on the Together Project priorities

Photo by: Wally Gobetz

Launched in January of this year, InterAction’s Together Project is an initiative designed to create a hub of solidarity and advocacy for U.S.-based NGOs confronting targeted regulations or discrimination, owing to their operating principles or religious faith.

As part of the project’s mission to support and represent its members, a team of advocates headed to Capitol Hill to engage policymakers in a conversation about the work of the Together Project and, more specifically, the project’s key priorities: the issues of de-banking and de-risking. The team met with Senate and House staff, on both sides of the aisle, to outline the project’s main priorities[i], preesent a section from InterAction CEO Sam Worthington’s Senate Foreign Relations Committee testimony, which highlighted the difficulties NGOs face when moving private resources internationally, and demonstrate the human impact of these policies and practices.

Through sharing the recent findings from Charity and Security Network’s financial access research, the empirical evidence demonstrated the extensive scale of the de-risking phenomenon and the impact on nonprofits (2/3 of all U.S. nonprofits that work abroad reported financial access difficulties). Syria Relief and Development’s recent case demonstrated the human impact of these controls, when an intermediary bank’s due diligence procedures halted the transfer of humanitarian funding earmarked for vital medical supplies. Additionally, the Wall Street Journal published a series of articles on de-banking, de-risking, and the damage caused to legitimate customers in a number of industries including the nonprofit sector.

Current anti-money laundering policies and regulations to combat the financing of terrorism endorse this unfair representation of all NGOs as inherently high risk. This, in turn, hinders nonprofits' ability to undertake vital humanitarian and development work overseas. However, there are solutions to resolve these problems and so, the Together Project team presented congressional staffers with three key recommendations:

  • Review the FFIEC Bank Examiners Manual to update language within the nonprofit section,
  • Review Department of Treasury guidance to provide further clarity and security to banks,
  • Keep abreast of developments within this sector and encourage Treasury's engagement with the World Bank and ACAMS work streams.

Looking ahead, the project team will continue the conversation with policy makers in the fall, to further support the U.S. government’s facilitation of American philanthropy and ensure nonprofits can continue their life-saving work without unfairly targeted financial exclusion. In terms of the broader strategies of the project, the steering committee continues to strengthen collective capacity - with the launch of the working group in the fall, build advocacy efforts beyond the Washington, D.C. area, provide educational opportunities for NGOs facing these challenges, and extend the dialogue with representatives from the financial sector.

On August 1st, the Together Project will host an expert briefing, delivered by experienced attorneys from Venable Law Firm’s nonprofit practice. This briefing will address common issues facing NGOs operating internationally including compliance, financial controls, adherence to economic sanctions and export controls, and implementation of effective employment procedures.




[i] De-risking policies and de-banking; material support; insurance and protection; and public image – changing negative perceptions.