Cutting funds to cut back terror- Proper due diligence recommendation paper submitted to the EU
While NGOs play a crucial role in international humanitarian work as well as in civil society, their unique structure makes them the perfect tool for terror organizations to use in order to expand their activities, legitimacy, and funding.
The ILF and the Lawfare project prepared a joint submission to the Commission of the European Union on the action plan for a comprehensive EU policy on preventing money laundering and terrorism financing.
European governments, humanitarian groups, and private funds often contribute and collaborate, mostly unknowingly, with terror-linked NGOs, due to a lacking or non-existent due diligence process. The submission encourages contributing bodies to adopt a risk-based approach to NGOs and suggests a number of policies meant to ensure a proper examination and documentation of various risk factors. These recommendations are the product of the ILF’s vast experience and familiarity with the methods of concealment commonly used by these terror-affiliated organizations and ways most efficient to expose them.
The suggested policies included an open-source search and what we call the ‘red and yellow flag approach’. By utilizing simple internet searches, it is possible to note if there are any indications of a connection between an NGO and a terror group, and thus ‘raise’ yellow or red flags. A yellow flag does not necessarily mean ceasing funding, however, once such a flag is raised, the potential funder must conduct an examination of those findings while thoroughly documenting the process, answers received, and conclusion. A decision to grant the funding should be based on this information and the process should be repeated periodically as well as when a grant is up for renewal.