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Compliance

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Charity Monitor

By using a well-known Third Party Charity Monitoring company for the US 501C3 ’s we offer unique transparency for regulatory and Bank partners so they know that you take regulatory compliance seriously. Additionally using a Third Party we offer our clients the ability to know what the rating a given Charity has in the view of the public.  

OFAC

 

Nonprofits may be exempt from various taxation liabilities, but are not exempt from following The Financial Crimes Enforcement Network (“FinCEN”) requirements to identify potential blocked accounts on the Specially Designated Nationals List (“SDN.”) In addition screening against OFAC’s consolidated SDN list is also required. 

The US Department of Treasury has provided guidance for Financial Institutions and Non-Profits to assess the risk profile each Non-Profit Organization carries based on the nature of the charity and the relationship between the donor and grantee.

One level of giving requires the desire for anonymity. The USA PATRIOT ACT specifically requires all companies involved in commerce to know their customer and their customer’s customer. This is known as KYC and KYCC.  These requirements extend to non-profits as well. ICL provides tools and management services to meet those requirements. ICL’s robust compliance policies and procedures enable us to match the needs of many donors and recipients.

 

Risk Mitigation 

ICL Data can provide insight and guidance to improve your organization’s risk profile. This is especially important when working with your Financial Institution to determine whether or not your risk profile is acceptable to your bank.  Many banks will simply close your account or not even allow you to domicile a relationship if they feel your organization exceeds their risk appetite. Risk comes in many forms. There are many types of risk banks have to deal with when it comes to safety and soundness practices. When dealing with charitable organizations the following risk rates the highest in terms of exposure:

1. Cross-Channel Risk

2. BSA/AML Risk

3. Reputational Risk

Even though it is common practice for charities to hire volunteers, they come with little safety and soundness practice skills. This is where ICL excels and everyone benefits. Part of ICL’s compliance regimen includes rigorous vetting practices. Such objectives include compliance education and awareness. Others include specialized automated software programs for us to test and monitor transaction activity and to ensure that not only are safety and soundness practices being met, but additionally, to ensure high-quality assurance standards for all concerned. Our objective is to ensure the intended gift gets to the rightful recipient.

 

BSA/AML- Regulatory Updates for 2024 

ICL Data honours the four pillars of a strong BSA/AML compliance program. The company was founded by several BSA/AML compliance officers with ACAMS backgrounds. ICL Data principles believe that with a strong compliance program, we offer better solutions to our clients and a better service to our BOFD and ODFI partners as they know all Enhanced Due Diligence “(EDD)”  on each client and the strictest code of ethics and regulatory principles are being followed at all levels of the company. We process with both reputation and transaction risk policies in mind. This assures our BOFD partners that we have limited all aspects of risk. As of April 2022, FinCEN is enforcing all commercial businesses regardless of the type that opens any type of banking relationship are now required to provide beneficial ownership information as well as managing directors (all control personnel) information. 

 

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