Palestine Monetary Authority

PALESTINE MONETARY AUTHORITY

Circular No. (128/2020)

To all banks operating in Palestine Date: Tuesday, June 16, 2020

Subject: Outputs of the Assessment of the Non-Profit Organizations Sector in Palestine

In line with the Palestine Monetary Authority's continuous commitment to maintaining financial stability in Palestine and mitigating the risks of money laundering and terrorist financing, it is updated that the sector of non-profit organizations is considered, according to international standards and recommendations, as a sector vulnerable to exploitation in money laundering and terrorist financing operations. This is due to the specific, unique, and distinctive features available to activities related to charitable work and the nature of activities conducted by these organizations, which are based on collecting funds from multiple sources and then using, re-transferring, or distributing these funds to other beneficiary entities. As a result of the spread of their activities and branches at the local and international levels, they have become a target of attraction and interest worldwide with the aim of penetrating them and exploiting the features they possess.

In the context of local cooperation and national efforts undertaken to strengthen the anti-money laundering and counter-terrorist financing framework for the non-profit organizations sector in the State of Palestine, a national risk assessment study was recently conducted on two sub-sectors: (the sector of civil bodies and charitable associations, and the sector of non-profit companies). The outputs and results of the national risk assessment for money laundering and terrorist financing in this sector are as follows:

1. The level of threats and consequences of money laundering in this sector is assessed as "medium," the level of terrorist financing threats is assessed as "low-medium," and the level of terrorist financing consequences is assessed as "medium-high." Additionally, the level of money laundering and terrorist financing vulnerabilities in this sector is assessed as "high." This included measuring the adequacy of supervisory measures taken to mitigate money laundering and terrorist financing risks, and the results showed the need to enhance supervisory and oversight practices in this sector and direct resources toward the high-risk sub-group.

2. Identification of the sub-group of non-profit organizations most exposed to exploitation in terrorist financing due to their activities or characteristics, according to the Financial Action Task Force (FATF) definition. This group does not exceed 3% of the total number of non-profit organizations in Palestine, as not all non-profit organizations can be considered high-risk.

3. Classification of the degree of exposure of non-profit organizations to money laundering and terrorist financing risks (high, medium, low), taking into account classifying those organizations as high-risk if they fall within the group and meet any of the following criteria:

• Being a branch of a foreign organization whose headquarters is in a high-risk country or a country under enhanced monitoring within the lists issued by the Financial Intelligence Unit, and/or having branches in those countries.
• Having financial relationships with high-risk countries or countries under enhanced monitoring.
• Or countries under continuous monitoring for compliance with Financial Action Task Force standards.
• Their annual revenue exceeds 100,000 US dollars, and their main activity falls under service activities, as they are organizations primarily working in the field of collecting or distributing funds. This includes programs focusing on housing, social services, education, and healthcare.
• The bank has filed a suspicious activity report regarding them to the Financial Intelligence Unit or received an inquiry and information request from competent authorities.

With the Palestine Monetary Authority's keenness to maintain the integrity of the non-profit organizations sector and ensure its continuity, and to guarantee that this sector or its organizations are not exploited contrary to their fundamental objectives, the Palestine Monetary Authority emphasizes the necessity to comply with the following measures and controls:

1. Adoption of special measures for opening bank accounts for non-profit organizations ensuring:

   a. Restricting the opening of bank accounts for non-profit organizations to the name and registration number specified in the registration and license certificate issued by competent authorities.

   b. Identifying and verifying the identity of the non-profit organization, its objectives, board members, authorized signatories, and beneficial owners, and enhancing this with necessary documents, while working to classify money laundering and terrorist financing risks for those organizations.

   c. Not opening more than one basic account for the same non-profit organization at the same bank, where a single main account is opened from which sub-accounts are derived for each specific activity or project, through which donations are recorded and expenditures are made.

   d. The organization's commitment to using its bank account in all its operations and financial activities.

   e. Inquiring about the organization's name, board members, and financial committee members on international and local sanctions and freezing lists.

   f. Linking the authority of account managers electronically on banking system signature screens to the signing authorities of the authorized signatories according to letters of authorization issued by competent authorities.

2. Taking the necessary supervisory measures and controls to monitor bank accounts of non-profit organizations and financial transactions executed on them, ensuring:

   a. No overlap of donations and expenditures between sub-accounts dedicated to projects, in addition to not conducting charitable activities under the personal name of any of the customers, heads, members, or employees of the non-profit organization.

   b. Freezing bank accounts and electronically blocking signatures immediately upon the expiration of the authorization of the authorized signatories, and/or immediately upon the inclusion of the organization or its authorized signatories on the sanctions and freezing lists in Palestine.

   c. Directing and encouraging those organizations to reduce reliance on cash, so that account funding sources are via checks or incoming transfers and remittances, while account usage (expenditure and withdrawal) is limited to checks payable to the first beneficiary or via outgoing transfers and remittances, while considering cash withdrawal operations for the organization's liquidity needs.

   d. Prohibiting non-profit organizations from receiving any electronic services that could move accounts, whether through credit and debit cards, internet banking, or mobile banking services.

   e. Prohibiting the execution of financial transfers outside Palestine without prior permission from the supervisory and competent authority.

3. Exercising enhanced due diligence towards high-risk non-profit organizations, ensuring the identification of the source of funds, the purpose of financial transactions, and the identity of payers and beneficiaries, and obtaining the necessary documents for this purpose.

4. Enhancing the effectiveness of monitoring suspicious activities and transactions of non-profit organizations according to specific policies and protocols defined in the bank's anti-money laundering and counter-terrorist financing programs.

5. Emphasizing that non-profit companies obtain the necessary approvals to receive donations, grants, and financing according to the mechanism specified by the Cabinet of Ministers decision issued in this regard in 2016.

6. Relying on the available information about civil bodies, charitable associations, and non-profit companies available on the Palestinian Ministry of Interior website, and on the database of the Ministry of National Economy for banks, when conducting due diligence and enhanced due diligence procedures regarding accounts belonging to these organizations.

---

Supervision Group Palestine Monetary Authority

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