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Anti-Terrorism Compliance: Resources

General Resources

The USA Patriot Reauthorization Act, Treasury Guidelines, and Executive Order 13224: An Update on Implications for Grantmakers
By Edgardo Ramos and Clifford E. Nichols III (Day, Berry and Howard, LLP )
Legal Dimensions of International Grantmaking,Third Quarter 2006
This clearly written overview of the changes created by the reauthorized Patriot Act and the implications of other counter-terrorism measures such as Executive Order 13224 and the revised U.S. Department of the Treasury Anti-Terrorist Financing Guidelines issued in late 2005 is a must-read for all international grantmakers. This installment of Legal Dimensions of International Grantmaking is written by attorneys Edgardo Ramos and Cliff Nichols of the law firm Day, Berry and Howard. [More]

Principles of International Charity
Treasury Guidelines Working Group, 2005
Developed by the Treasury Guidelines Working Group, a Council on Foundations-led working group of more than 40 U.S. charitable sector organizations, as an alternative to the U.S. Treasury Department’s Voluntary Guidelines. The eight fundamental Principles of International Charity were presented to the Treasury Department in March 2005. Read the press release. Email usig@cof.org to request a copy in the mail.
Download here (PDF).

Federal Anti–Terrorism Measures: How Foundations and Corporate Grantmakers are Responding
By Rob Buchanan, director, International Programs, Council on Foundations. International Dateline, First Quarter 2005
International grantmakers are responding to the federal anti-terrorism policies in many ways. The Council’s International Programs staff conducted an informal survey of a representative sample of approximately thirty-five of the Council’s international grantmaking members to determine what, if any, changes they had made or were planning to make in their procedures because of the government’s anti-terrorism actions.
Download here.

Handbook on Counter-Terrorism Measures: What U.S. Nonprofits and Grantmakers Need to Know
Independent Sector, InterAction, the Council on Foundations and the Day, Berry & Howard Foundation, 2004
Describes in plain language the most critical U.S. Government counter-terrorism measures currently in effect relevant to U.S. non-profits and grantmakers.
Download here (PDF).

Grantmaking in an Age of Terrorism: Some Thoughts about Compliance Strategies
B y Janne G. Gallagher, vice president and general counsel, the Council on Foundations, Legal Dimensions of International Grantmaking, 2nd Quarter 2004

This article provides an overview of the current state of anti-terrorism legislation and offers some thoughts on how grantmakers might comply with it.
Download here

Seeking a Safe Harbor: Using Technology to Comply with Anti-Terrorism Measures
By Martin B. Schneiderman, president of Information Age Associates, Foundation News and Commentary, May-June 2004
This article discusses the uses of technology to facilitate compliance with the USA Patriot Act and Executive Order 13224.
Download here

International Grantmaking After September 11th: Dealing with Executive Order 13224 and the USA Patriot Act
By Timothy R. Lyman, Michael G. Considine and Jennifer L. Sachs. Legal Dimensions of International Grantmaking, Fall 2002.

This article looks at the effects of the U.S. Government's anti-terrorism measures and offers ways of dealing with them.
Download here (PDF).

Anti-terrorism Certification

The Debate Over Anti-terrorism Certification
By Andrew Schulz, deputy general counsel, Council on Foundations. Legal Dimensions of International Grantmaking, Third Quarter 2005
This article discusses why some charities believe that certification is a valuable tool, while others argue that it is worthless and potentially dangerous. Also included are examples of certification language.
Download here.

Treasury Department's Voluntary Guidelines

Charitable Sector Group Asks U.S. Treasury to Withdraw Anti-Terrorism Financing Guidelines
The Treasury Guidelines Working Group sent a letter [pdf] to the U.S. Department of Treasury Secretary Paulson on December 18, 2006, requesting the Treasury Department to withdraw its revised “Anti-terrorist Financing Guidelines: Voluntary Best Practices for U.S.-based Charities” issued in September 2006. [more]

Treasury Guidelines Working Group Comments on Revised U.S. Department of Treasury Anti-Terrorist Financing Guidelines
The Treasury Guidelines Working Group submitted comments to the Treasury Department in February 2006 in response to the revised “Anti-Terrorist Financing Guidelines: Voluntary Best Practices for U.S.-based Charities” issued on December 5, 2005.
Download here (PDF).

Council on Foundation Comments on Original U.S. Department of Treasury Anti-Terrorist Financing Guidelines
The Council on Foundation submitted comments to the Treasury Department in June 2003. The comments requested that Treasury replace the “Anti-Terrorist Financing Guidelines: Voluntary Best Practices For U.S.-Based Charities,” with a risk-based approach. The Council argued that a risk-based approach would help grantmakers identify the level of due diligence required for a grant based on a balancing of risk factors.
Download here (PDF).

Legal Background and Discussion of the U.S. Treasury Department Anti-Terrorist Financing Guidelines: Voluntary Best Practices for U.S. Based Charities
By Patterson, Belknap, Webb & Tyler LLP
Download here (in PDF)

U.S. Treasury’s Proposed Voluntary Guidelines for U.S.-Based Charities
A memo by Silk, Adler & Colvin
Download here (PDF).



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