Survey on perception of Terrorist Financing Risks in the NPO Sector

We are completing a Terrorist financing risk of the NPO sector, in line with the requirements of FATF R8 and IO.10. The assessment is based both upon quantitative and qualitative data. Please note, the questions in this survey only relate to terrorist financing risks.

As part of the risk assessment, we are surveying representatives from government, civil society and financial institutions.

The following page starts with the definition of NPO. If you manage no entities which meet this description, please answer ‘0’ in box 1 and return the form.

If you manage any entities which meet the description of NPO, please answer all of the remaining questions. If you feel there is no risk, vulnerability etc, please answer ‘none’. If you do not know the answer, please answer ‘not known’.

We may contact you to discuss your responses in more detail.

We will not name you in the report, but we will state that we spoke to your institution. We will not indicate in the report that a particular response was received from a particular financial institution, but we may say that it was received from a trust services provider or management company.

Company details

Name of company *

Agency *

Position *

NPO Survey details

1. How many NPO clients do you manage (estimate if necessary). (if zero, please ignore all following questions and return the form)

2. What percentage of your clients are NPOs (estimate if necessary).

3. What is the total value of the assets held by NPOs that you manage (estimate if necessary).

4. What is their legal form? Please provide an answer for each of your NPO clients.

5. What is the purpose / activity of your NPO clients (e.g. education, religion, poverty relief). Please provide an answer for each client.

6. What are the foreign links of the NPOs that you manage? Please indicate all that apply, and the number of your clients they apply to (e.g. if 3 of your clients received income from foreign sources, answer 3 in the box)

Receive income from foreign sources

Distribute funds in foreign countries

Beneficial owners or controllers are foreign citizens / not resident in your jurisdiction

Risk policy for your NPO clients

8. If you answered ‘d’ to Q7, what features of the NPO determine its risk rating? Please provide the major factor(s). If you did not answer ‘d’, please go to Q9.

9. What are the most significant influences in determining your risk policies and risk appetite towards NPOs that you manage?

Perception of TF risks to your NPO clients

In your opinion, what is the threat to your NPO clients from terrorist financing? ‘Threat’ – A person or group of people, object or activity with the potential to cause harm. Threat is contingent on actors that possess the capability and the intent to do harm. For example, is it high, medium or low? What factors have contributed to your conclusion?

In your opinion, what is the nature of the TF threat to your NPO clients? This may include your opinion on the organisations, entities or individuals likely to abuse NPOs for TF purposes; or your opinion on the ways in which such abuse is likely to occur.

In your opinion, what are the vulnerabilities of your NPO clients to terrorist financing? ‘Vulnerability’ – things that can be exploited by the threat or that may support or facilitate its activities. Vulnerability in the NPO sector can exist at either the organisation or sectoral level. For example, is it high, medium or low? What factors have contributed to your conclusion?

In your opinion, what is the overall terrorist financing risk of your NPO clients? ‘Risk’ – the likelihood that a vulnerability may be exploited by the threat with negative consequences. For example, is it high, medium or low? What factors have contributed to your conclusion?

What features of your NPO clients are or may be associated with greater TF risks? For example, the type of NPO, its objectives, activities, location, its project, fundraising practices, sources of funding or other identifiable information.

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