Anti-Terrorism Compliance

Updated January 23, 2009

This section provides a brief description of U.S. government anti-terrorism initiatives along with a list of resources made available by the Council on Foundations to provide general guidance to grantmakers responding to federal anti-terrorism due diligence requirements.

Federal Actions

• Executive Order 13224
• USA Patriot Act
• U.S. Treasury Department "Anti-Terrorist Financing Guidelines: Voluntary Best Practices for U.S.-Based Charities"

Resources

General Resources

• The USA Patriot Reauthorization Act, Treasury Guidelines, and Executive Order 13224: An Update on Implications for Grantmakers (2006)
• Principles of International Charity (2005)
• Federal Anti–Terrorism Measures: How Foundations and Corporate Grantmakers are Responding (2005)
• Handbook on Counter-Terrorism Measures: What U.S. Nonprofits and Grantmakers Need to Know (2004)
• Grantmaking in an Age of Terrorism: Some Thoughts about Compliance Strategies (2004)
• Seeking a Safe Harbor: Using Technology to Comply with Anti-Terrorism Measures (2004)
• International Grantmaking After September 11th: Dealing with Executive Order 13224 and the USA Patriot Act (2002)

Anti-terrorism Certification

• The Debate Over Anti-terrorism Certification (2005)

Treasury Department's Voluntary Guidelines

• Funding Charitable Work in Sanctioned Countries (January 2009)
• Treasury Guidelines Working Group letter [pdf] submitted 18 December 2006, to the Treasury Department in response to September 2006 Guidelines
• Council on Foundations press release issued 18 December 2006
• Revised Anti-Terrorist Financing Guidelines: Voluntary Best Practices For U.S.-Based Charities released September 2006
• Treasury Guidelines Working Group Comments on Revised U.S. Department of Treasury Anti-Terrorist Financing Guidelines (February 2006)
• Council on Foundation Comments on Original U.S. Department of Treasury Anti-Terrorist Financing Guidelines (2003)
• Legal Background and Discussion of the U.S. Treasury Department Anti-Terrorist Financing Guidelines: Voluntary Best Practices for U.S. Based Charities (2003)
• U.S. Treasury’s Proposed Voluntary Guidelines for U.S.-Based Charities (2002)