From the Fact Sheet:
Charities and other NPOs are subject to federal and state reporting requirements and regulatory oversight. For example, charities report specific information annually on IRS Form 990 regarding their stated mission, programs, finances (including non-cash contributions), donors, activities, and funds sent and used abroad.1Many NPOs also adhere to voluntary self-regulatory standards
and controls to improve individual governance, management, and operational practice, in addition to internal controls required by donors and others. Although the CDD rule does not require the collection of this specific information, the following customer information may be useful for banks in determining the ML/ TF risk profile of charities and other NPO customers:
• Purpose and nature of the NPO, including mission(s), stated objectives, programs, activities, and services.
• Geographic locations served, including headquarters and operational areas, particularly in higher-risk areas where terrorist groups are most active.
• Organizational structure, including key principals, management, and internal controls of the NPO.
• State incorporation, registration, and tax-exempt status by the IRS and required reports with regulatory authorities.
• Voluntary participation in self-regulatory programs to enhance governance, management, and operational practice.
• Financial statements, audits, and any self-assessment evaluations.
• General information about the donor base, funding sources, and fundraising methods, and for public charities, level of support from the general public.
• General information about beneficiaries and criteria for disbursement of funds, including guidelines/standards for qualifying beneficiaries and any intermediaries that may be involved.
• Affiliation with other NPOs, governments, or groups.