Treasury Guidelines Working Group Submits Comments on U.S. Department of Treasury Anti-Terrorist Financing Guidelines

On February 1, 2006, the Treasury Guidelines Working Group submitted comments in response to the invitation for public comments on the revised “Anti-Terrorist Financing Guidelines: Voluntary Best Practices for U.S.-based Charities” issued on December 5, 2005. Download the comments (in PDF).

The Treasury Guidelines Working Group is a broadly representative group of more than 40 U.S. charities, foundations, religious organizations, corporations, umbrella associations, watchdog groups and advisors. The Working Group was created in the spring of 2004 and is coordinated by the Council on Foundations. The group developed the Principles of International Charity (in PDF) that identifies eight principles to guide the anti-terrorism efforts of charities. The Principles of International Charity were submitted to the Treasury Department in March, 2005.

The Treasury Guidelines Working Group requested that the Treasury Department withdraw the revised Guidelines and endorse in their place the Principles of International Charity. The Working Group’s position is based on three principal concerns: 1) that the revised Guidelines contain provisions which suggest that charitable organizations are agents of the government, 2) that the revised Guidelines suggest the collection of more information on more individuals and organizations than did the initial Guidelines, and, 3) that the revised Guidelines do much more than offer guidance to charities that might be helpful in achieving compliance with sanctions administered by the Office of Foreign Assets Control.

• Download the Comments as submitted to the Treasury Department (in PDF)
• Download the Principles of International Charity
• Read the revised "Anti-Terrorist Financing Guidelines: Voluntary Best Practices For U.S.-Based Charities."
• Download Council on Foundation Comments on Original U.S. Department of Treasury Anti-Terrorist Financing Guidelines (June 2003)
  The Council recommended to the Treasury Department on June 20, 2003, that it replace the Anti-Terrorist Financing Guidelines: Voluntary Best Practices For U.S.-Based Charities, with a risk-based approach that would help grantmakers identify grants that present a greater risk for diversion and that would base the level of due diligence required for a grant on a balancing of risk factors.