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  • Obama's Cairo Pledge on Charitable Giving Rules Opens Door to Reform | Charity & Security Network
    with American Muslims to ensure that they can fulfill zakat Zakat the religious obligation to give to those in need is one of the pillars of Islam Muslim donors in the U S have been frustrated by indefinite freezing of assets when U S Muslim charities have been shut down by the Department of the Treasury scrutiny from law enforcement about their support of charities and fear of being prosecuted if their donations go to charities that are later accused of supporting terrorism Fear of being shut down based on vague laws that provide no due process for accused charities has had negative impacts throughout the U S nonprofit sector Participants in the Charity and Security Network have made recommendations to reform these laws and policies The Charity and Security Network statement responding to Obama s remarks said In the U S our national security laws have made both zakat and the operations of charities more difficult for both Muslim and non Muslim groups As examples it cited the overbroad definition of prohibited material support of terrorism which conflicts with Red Cross standards of non discrimination in aid and development It also cited the fact that a charity merely accused of supporting terrorism can be shut down by the Treasury Department and have its assets frozen indefinitely with no opportunity for the charity to see the evidence against it or defend itself against the allegations before an independent tribunal The statement also noted that an estimated 20 7 million in frozen funds which includes zakat donations remains blocked by Treasury The statement from Muslim Advocates said they welcome the opportunity to work with the Obama Administration to reform policies begun under the Bush Administration that continue to create hurdles to the philanthropic community It called for withdrawal of Treasury s problematic guidelines for nonprofits a new system for dealing with frozen charitable funds and ending law enforcement policies that probe law abiding American Muslims about their charitable giving and associations with lawful charitable entities There was negative reaction to Obama s remarks from the Center for Security Policy whose statement made the broad claim that zakat payments have very often gone to charities that support terrorist organizations Accusing the entire charitable sector of complicity with terrorists is both unproductive and unfair and feeds the perception that the west is at war with Islam Muslim Public Affairs Council Executive Director Salam Al Marayati told the New York Daily News The perception that giving to charities is financing terrorism has to be debunked It hurts America 100 Muslim leaders from around the world published a joint statement with thoughts and reactions to the speech There was general support and praise for Obama s points about combating extremism promoting communication religious tolerance and economic development In his speech Obama noted that the trauma of the 9 11 attacks provoked understandable fear and anger and in some cases it lead us to act contrary to our traditions and ideals We are taking steps of

    Original URL path: http://www.charityandsecurity.org/news/Obama_Cairo_Pledge_Charitable_Giving_Rules_Reform (2016-02-16)
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  • Clinton's Speech Stresses "A New Generation" for State and Civil Society Relations | Charity & Security Network
    will eventually be considered on the same par as equal partners with defense because I know what a difference this work can make Clinton said Acknowledging that the challenges facing the United States will not be solved by governments alone she said I m committed to increasing the State Department s engagement with the private sector and with civil society Clinton also applauded the leadership generosity and standard of innovation and creativity that NGO s and philanthropic foundations have repeatedly demonstrated while responding to global crisis We embrace collaboration and become more receptive to the ideas and approaches that you will bring to us she added Calling for an honest conversation about what works and what doesn t Clinton said the revitalized relationship would be facilitated by the State Department s Global Partnership Initiative The Initiative will be lead by Elizabeth Bagley a former senior advisor to Secretary Madeline Albright and ambassador to Portugal Working with her is Kris Balderston a Clinton staffer who also worked in Bill Clinton s administration According to Clinton the three primary benefits for organizations partnering with the State Department are Bring people from different regions and sectors to communicate on issues of common interest Create new programs provide training or technical assistance and develop innovative solutions Collaborate with NGOs and other organizations to reduce redundant programs and implement strategies Clinton s remarks were welcomed by grantmakers and NGO representatives in the audience There is a guarded optimism among NGOs that Clinton and other State Department officials will approach this new generation of public private partnerships with sensible counterterrorism policy choices such as adhering to the State Department s own Guiding Principles on Non Governmental Organizations Issues Humanitarian Access Material Support Financial Action Task Force FATF Financial Access Peacebuilding Countering Violent Extremism Click Here For

    Original URL path: http://www.charityandsecurity.org/news/Clinton%27s_Speech_New_Generation_Civil_Society_Relations (2016-02-16)
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  • List of U.S. charities designated and/or shut down by Treasury | Charity & Security Network
    or economy of the United States IEEPA is the legal authority for Executive Order EO 13224 issued by President George W Bush on Sept 24 2001 EO 13224 declar ed a national emergency based on the 9 11 attacks and directed Treasury in consultation with the Attorney General and Secretary of State to designated SDGTs and take action to freeze all assets subject to U S jurisdiction Designation may be of a terrorist organization or if Treasury finds a group has Provided material support to an SDGT To be otherwise associated with an SDGT defined in subsequent regulations as owned or controlled by an SDGT or to act for or on behalf of it For more about the legal authority to designate a charity as a SDGT see Summary of Economic Sanctions Laws and Regulations Authorizing Treasury to Shut Down Charities U S Charities Shut Down Pending Investigation by the Department of Treasury Al Haramain Islamic Foundation 1 19 04 Later designated on 9 9 04 Benevolence International Foundation 12 14 01 Later designated on 11 02 Global Relief Foundation 12 14 01 Later designated on 10 18 02 KindHearts for Charitable and Humanitarian Development Inc 2 19 06 In May 2012 a settlement was reached by the charity and Treasury allowing KindHearts to pay its debts and distribute the remaining funds among a list of approved charities before it dissolves At that point Treasury will remove KindHearts from its terrorist list and pay its attorneys fees Neither side admitted to any wrongdoing Designated Only Goodwill Charitable Organization 7 24 07 Holy Land Foundation 12 01 01 re designated 5 02 Islamic American Relief Agency 10 13 04 Tamil Rehabilitation Organization 11 15 07 Tamil Foundation 2 11 09 List of all charities impacted by the Department of Treasury is

    Original URL path: http://www.charityandsecurity.org/background/US_harities_designated_shut_down_by_Treasury (2016-02-16)
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  • Kay Guinane Answers Rep. Keith Ellison’s Questions about U.S. charities Impacted by Treasury’s Regime. | Charity & Security Network
    known about some of the evidence is cause for concern Criminal trials have required the government to disclose its evidence providing the general public a glimpse of the kind of evidence Treasury considers when shutting down a charity This evidence has often been of poor quality based on substandard intelligence or faulty translations The evidence used to designate the Holy Land Foundation is a case in point In July 2004 Holy Land asked the Department of Justice Inspector General to investigate allegations that the Federal Bureau of Investigation FBI used erroneous translations of sensitive Israeli intelligence material as the crux of its designation 9 Instead of launching an investigation the Justice Department indicted Holy Land and its top officials 10 A June 2006 article in the Los Angeles Times 11 revealed details of these translation discrepancies It said the prosecution argued that many of the orphans supported by Holy Land were children of suicide bombers citing an orphans book seized from Holy Land s office The Los Angeles Times review of this document identified 69 of 400 orphans in the book labeled as children of martyrs Noting that the term martyr is used broadly to include common accidents and incidents the article quoted a sworn statement by the former head of Holy Land s Gaza office who said social workers interviewed all 69 families and found only 4 had immediate family members that died from making bombs Of the remaining 65 orphans 12 lost family members to Israeli troops 8 were killed by Palestinians for allegedly collaborating with Israel and the remaining 45 were victims of robberies heart attacks accidents and other non political deaths Defense motions filed in February revealed significant discrepancies between transcripts of a 1996 FBI wiretapped conversation and the official summary anti Semitic remarks attributed to Holy Land executive director Shukri Abu Baker in the summary were not in the actual transcripts The government was unable to prove support for terrorism when it prosecuted Benevolence International Foundation BIF In January 2002 BIF filed suit 12 to contest its designation In April 2002 the government charged BIF and its executive director with making false statements in their appeal by denying association with al Qaeda In February 2003 Judge Suzanne B Conlon dismissed the charges against BIF 13 ruling that the prosecution had failed to connect the dots to prove a relationship between BIF its staff and bin Laden To provide further background about concerns on these designations I have attached a March 2006 report I wrote for OMB Watch Muslim Charities and the War on Terror Top Concerns and Status Update My understanding is that one of the charities KindHearts had its assets frozen in 2006 without a warrant and without probable cause A federal judge ruled recently that this was improper Could you please comment Answer Judge James Carr of the Federal District Court for the Northern District of Ohio in a 100 page opinion set out the constitutional basis for requiring a warrant based on probable cause before a charity s funds can be seized frozen by Treasury In doing so he brought the economic embargo sanctions scheme originally intended to be directed at nation states into a framework that can be constitutionally applied to U S citizens and organizations Treasury s sanctions powers are based on Executive Order 13224 which draws its authority from the International Emergency Economic Powers Act IEEPA The law was written to authorize the executive branch to impose sanctions against foreign nations and the asset blocking powers were intended to create negotiating leverage in the conduct of U S foreign policy This statutory scheme was expanded to apply to non state terrorist organizations and individuals interfering with the Middle East peace process during the Clinton administration in Executive Order 12947 and further expanded in Executive Order 13224 to apply to Specially Designated Global Terrorists Once they are shut down U S charities have no leverage for negotiating with the government for release of their assets Judge Carr recognized that designation and asset blocking has effectively shut KindHearts down He said nothing in our Fourth Amendment jurisprudence or constitutional tradition supports complete elimination of the probable cause prior judicial review and warrant requirements On May 10 2010 Judge Carr ordered new proceedings for the government to seek the probable cause warrant However this remedy only applies to the KindHearts case Carr said I leave to Congress the responsibility for considering and adopting the appropriate structure for pre blocking warrant and probably cause standards that would comply with the Fourth Amendment Here however I am not delineating pre seizure requirements I am rather constructing a remedy for the constitutional violation in this case p 16 fn 7 Has the Obama administration applied the current rules to shut down charities or freeze any charitable assets Do you have any reason to believe that the Treasury Department has changed its approach on this issue under the Obama administration Answer After President Obama took office on Feb 9 2009 the Treasury Department shut down the Maryland based Tamil Foundation as a supporter of the Liberation Tigers of Tamil Eelam LTTE 14 That is the only charity designation either U S or foreign that I could find on the Treasury website that occurred after President Obama took office It was deemed to be an affiliate of the Tamil Rehabilitation Organization which was shut down in 2008 The Department of Treasury has not changed its approach to charities since Obama took office The same officials that developed and implemented policy under President Bush continue to do so Despite promises of dialog from Assistant Secretary for Terrorist Financing David S Cohen made in a July 2009 meeting Treasury has been unwilling to discuss our proposals relating to frozen funds due process or clear standards for designation Treasury officials have also made it clear they will continue to promote their Anti Terrorist Financing Guidelines despite the fact that the U S nonprofit sector has made it clear the Guidelines do more harm than good In a recent letter to the Treasury Guidelines Working Group Chip Poncy head of the Office of Terrorism and Financial Intelligence indicated that Treasury is working on a new version of the Guidelines aimed at high risk areas His letter lists Muslim majority countries as examples of high risk areas While it is helpful that Treasury recognizes problems their enforcement policies create for legitimate charities the agency has been indifferent to collateral damage it causes telling us the solution to that problem lies with Congress Treasury officials also continue to make sweeping statements about the role of charities and the dangers of being exploited by terrorists failing to acknowledge the difference between highly regulated U S charities and less regulated charities in some other parts of the world Treasury also fails to acknowledge the serious issues at hand by claiming it is all just a misunderstanding that can be cleared up with more outreach However further explanation of flawed policies will not undo the flaws For example Treasury s proposal for what it calls alternative delivery mechanisms as demonstrated in a pilot program it carried out with USAID and a specially created group American Charities for Palestine has serious flaws but Treasury continues to promote it despite objections from the U S charitable sector This model essentially requires a private charity to funnel contributions from private citizens through USAID This structure violates the principles of independence of the nonprofit sector subjects all individuals associated with a charitable project to having their personal information entered into U S intelligence databases and ignores due diligence based on on the ground investigations and assessments It is too fundamentally flawed to ever become a widespread solution to the problems charities and government confront when aid is needed in conflict zones The alternative delivery mechanism incorrectly assumes there are no conditions under which the U S charitable sector can provide aid and development in conflict zones without supporting terrorism either directly or indirectly This ignores a host of due diligence efforts that go much further than the government s computer based data searches Are these charitable organizations not entitled to due process of law Perhaps the desire to act quickly and freeze assets is understandable but shouldn t these organizations have an opportunity to be heard and be able to present evidence in their defense What are the due process requirements Answer U S charitable organizations are constitutionally entitled to due process of law but current Treasury rules and enforcement policies deny them these rights The only current due process requirement is that a charity can write a letter to Treasury asking it to reconsider its decision 15 There is limited access to funds to pay for legal defense or to learn about the evidence it must rebut Appeals to federal court involve only limited review For example in 2007 in the case of the Islamic American Relief Agency IARA USA the U S Court of Appeals for the District of Columbia upheld the designation saying that w e may not substitute our judgment for OFAC s 16 When the government needs to act quickly to prevent assets that may be subject to IEEPA sanctions from being transferred outside the jurisdiction of the U S government it has a wide array of tools it can use It is not necessary to freeze charitable funds indefinitely For example a trustee could be appointed to take control of the funds and make sure they are only spend on legitimate activities and are not transferred outside the U S The United Kingdom s Charity Commission uses such a system An example of overuse of the most drastic remedy can be seen in the case of the IARA USA The group s attorney made repeated requests over a two year period for release of funds for humanitarian and disaster aid including assistance for victims of Hurricane Katrina These requests included offers to change their governance structure financial accounting and personnel In a Feb 7 2005 letter from its attorney Shereef Akeel IARA USA said This organization would even consider some sort of reasonable monitoring program imposed by the government Instead of helping IARA USA restructure in a manner that would comply with the law and allow people in need to receive the benefit of its services Treasury denied the request Is charitable giving that seeks to fight poverty in Muslim majority countries able to reach the people who need help Or does federal law create a chilling effect on donations occur where by American Muslims become less likely to donate Answer Charities are having great difficulties delivering aid to people in need in many Muslim majority countries The problem goes well beyond the reduced donations caused by the chill on U S Muslim donors to include operational barriers that disproportionately impact Muslim populations These operational problems include the inefficient and obscure licensing processes at Treasury and Commerce Departments the chilling impact of Treasury s enforcement actions against charities the lack of an adequate humanitarian exemption to the definition of material support of terrorism long delays by banks in making financial transactions and more For example at a May 12 2010 panel discussion sponsored by the Muslim Public Affairs Council and the Charity and Security Network Ellen Willmott Deputy General Counsel of Save the Children described problems her organization has had providing psychological services to children in Gaza Because Hamas controls the Education Ministry Save the Children cannot provide services to children in the public schools In addition she said the group was unable to dig a well for a village in Somalia because someone from al Shabaab might come along and get a drink of water Please describe what precisely occurs procedurally and practically after assets of a charitable organization are frozen Is there an appeal process Answer Most of the process following designation of U S charities has involved correspondence between Treasury and the charity s legal representative after Treasury has been asked to reconsider its decision The next stage in the process is appeal to federal district court The best description of the details of this process are found in the Aug 18 2009 federal court ruling in KindHearts for Charitable and Humanitarian Development Inc v Timothy Geithner et al Case No 3 08CV2400 The judge ruled that Treasury s seizure of KinkHeart s assets without notice or means of appeal is a violation of the Fourth and Fifth Amendments KindHearts was shut down by the Treasury Department pending investigation on Feb 19 2006 To date it has not been designated as a supporter of terrorism The timeline below is based on information in the court ruling It details the issues and procedural history of the case Note Page numbers for quotes refer to text of the court s opinion OFAC refers to Treasury s Office of Foreign Assets Control From Freezing Assets Pending Investigation to Provisional Determination 1 22 2002 KindHearts for Charitable Humanitarian Development incorporated in Todedo Ohio with the goal of providing humanitarian aid without regard to religion or political affiliation 2002 to 2006 KindHearts seeks guidance from Treasury and implements Treasury s Anti Terrorist Financing Voluntary Guidelines Jan Feb 2006 Department of Justice serves grand jury subpoenas on KindHearts board members and accountants Ernst and Young requiring them to produce all records relating to KindHearts from January 2002 to Feb 17 2006 2 19 2006 OFAC freezes about 1 million in KindHearts assets and executes search warrant seizing all records computers equipment publications from headquarters and residence of President Khaled Smaili 2 19 2006 OFAC sends blocking notice to KindHearts stating 1 all property blocked pending investigation into whether KindHearts is subject to designation pursuant to Executive Order 13224 for being controlled by a citing for or on behalf of assisting in or providing financial or material support to and or otherwise being associated with Hamas 2 no prior notice provided because OFAC determined assets could be transferred making block freeze ineffectual and 3 KindHearts could challenge action by sending a letter stating its position and providing evidence to the Director of OFAC 2 19 2006 OFAC releases a press release 3 with more specific information than blocking notice Alleges that KindHearts officials and fundraisers had coordinated with Hamas leaders and made contributions to Hamas affiliated organizations including such organizations in the West Bank and Lebanon The press release asserted that KindHearts was founded to replace the Hamas affiliated Holy Land Foundation for Relief and Development HLF and the al Qaida affiliated Global Relief Foundations GRF p 7 4 2006 KindHearts attorney sends letter to OFAC opposing freezing assets but OFAC failed to respond to it p 7 11 29 2006 KindHearts attorney requests copy of OFAC administrative record in the case but It received no response p 7 5 27 2007 OFAC notifies KindHearts that it had made a provisional determination that KindHearts is a Specially Designated Global Terrorist and for the first time acknowledged receiving KindHearts challenge to the block pending investigation p 8 There is no provision for a provisional determination in IEEPA or Treasury regulations The notice also included 35 unclassified documents OFAC relied on It indicated classified and privileged information was also used and provided a three page summary of the classified evidence The OFAC letter provided no explanation of the specific charges it was considering against KindHearts or why it though the evidence supported a potential designation p 8 However it said KindHearts could present additional information before a final determination and that OFAC would forward any new non classified information for KindHearts response KindHearts Ongoing Attempted Defense at OFAC 2 2006 to 2 2008 OFAC denies license to allow KindHearts to use blocked funds to pay its attorneys 6 14 2007 KindHearts requests access to its own records now held by OFAC and the Department of Justice It also seeks access to the full classified record used by OFAC 6 25 2007 KindHearts sends OFAC a 28 page submission in which KindHearts attempted to in its words guess at and address OFAC s concerns It attached to that a 1369 page submission of supporting evidence OFAC never responded to this submission p 9 6 27 2007 KindHearts asks OFAC for declassification review of evidence used in blocking notice 8 10 2007 OFAC agrees to conduct declassification review and says it will give KindHearts 30 days to respond once material is provided Did not specify when review would be completed 8 13 2007 KindHearts requests further clarification of charges against it and an extension of time until forty five days after the completion of the declassification review KindHearts stated it needed the extension to receive meaningful process p 10 8 14 2007 OFAC denies KindHearts request for access to its own documents saying U S Attorney s Office prosecutors has most of them Ongoing OFAC claims it misplaced the June 25 2007 submission It does not however state what constituted misplacing how it happened or may have happened or when if ever and how it located the submission p 9 fn 4 4 2008 U S Attorney s Office provided KindHearts with an electronic copy of a subset of the seized documents but did so subject to stringent conditions Under a protective order KindHearts members and officers could not view the documents without court approval and KindHearts counsel could not print or electronically copy and documents p 9 fn 3 8 16 2007 OFAC tells KindHearts it may contact employees in preparing a defense but any documents discovered are blocked property that cannot be used without a license from OFAC and counsel must give OFAC identifying information about it KindHearts counsel objects in letters in October and December 2007 12 26 2007 OFAC approves license allowing KindHearts counsel to receive copies of blocked documents necessary for them to provide legal services to KindHearts p 11 6 2008 OFAC changes policy on attorney s fees after consituttional challenge in another case allowing KindHearts

    Original URL path: http://www.charityandsecurity.org/background/Kay_Guinane_Answers_Keith_Ellisons_Questions (2016-02-16)
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  • What Happens to a Charity After an FBI Raid | Charity & Security Network
    food water temporary shelter to the victims in the aftermath of an emergency but also does long term development assistance in communities by building schools water treatment plants and providing clean water to neighborhoods as well as workshops for low income women for low income neighborhoods Like other charities raided by the government the effects of the raid were not limited to the charity Many of LIFE s donors and partner groups were visited and questioned by government officials Alomari said law enforcement officials targeted their large donors asking Why are you donating to LIFE A lot of our donors come from the immigrant communities who are used to dictatorships that when a local policeman or security person comes to their door knocks on their door they re immediately scared that they might go to jail for something And so many of our donors our large donors have told us because of these visits we can t donate anymore LIFE and an Arab Gulf charity had planned on partnering to rebuild an Iowa clinic in 2008 after the flooding left thousands in Iowa in need of assistance but the project failed after a State Department employee told the charity not to deal with LIFE Before 9 11 LIFE had a good relationship with the Department of Treasury To conduct relief work in Iraq during the 1990s a special license from Treasury s Office of Foreign Assets Control OFAC was required T hroughout the 90s we applied to OFAC and we received licenses We were one of the very few if only American Muslim organizations that was licensed by the Iraqi Red Crescent and by the Treasury Department to deliver medical supplies and humanitarian aid to Iraq at the time Alomari said Alomari is cautiously optimistic about the future and has

    Original URL path: http://www.charityandsecurity.org/background/What_Happens_to_a_Charity_After_an_FBI_Raid (2016-02-16)
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  • Analysis: In a Bad SPOT: Why a Military Database for NGOs Is Impractical | Charity & Security Network
    record for contractors in Afghanistan and Iraq Why SPOT is Problematic for NGOs Requiring NGOs to supply intimate personal details about their international and local employees to a military database is both dangerous and impractical SPOT was designed for military officials to manage their defense contractors and not for NGOs who often employ local civilians SPOT permanently stores detailed information about a defense contractor s personnel including but not limited to his her full name contact information email address passport data government ID number addresses for employer and next of kin and blood type Another SPOT category specifically asks which military operation the grantee is working for The majority of NGO staff operating in Afghanistan and Iraq is locally hired and do not possess the information required by SPOT International NGO staff may be hesitant to provide personal information knowing that it will be stored indefinitely and shared with other agencies and governments for intelligence gathering purposes In places where both military and NGOs are independently providing relief services NGO managers forced to collect sensitive personal data for a government database may undermine their relationships with local actors The security of all NGO employees can be threatened if they are perceived by the local community to be an agent of the military Speaking at an event in May 2010 3 Deputy General Counsel for Save the Children USA Ellen Willmott shared her concerns about SPOT It is a military database It is owned operated maintained by the Department of Defense the US Army to be exact It is a database that is not confidential it is subject to sharing of information with other U S Government agencies including law enforcement foreign government agencies and the like We are being asked to input personal sensitive information of our staff the staff

    Original URL path: http://www.charityandsecurity.org/news/Analysis_In_a_Bad_SPOT_Why_Military_Database_for_NGOs_Is_Impractical (2016-02-16)
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  • Collateral Damage: How the War on Terror Hurts Charities, Foundations, and the People They Serve | Charity & Security Network
    charities and as they look to develop more equitable policies that protect the inherent rights of charities and the people the organizations serve This paper is the result of collaborative research conducted by OMB Watch and Grantmakers Without Borders We believe charities in the United States and throughout the world play a key role in democratic systems by giving citizens a vehicle for participation providing tools and information that help people get involved and delivering assistance to those in need Since Sept 11 2001 we have witnessed counterterrorism programs erode the freedom and ability of charities and their funders to carry out their missions and improve the lives of the world s people We believe that this is damaging civil society in the United States and negatively impacting the nation s reputation and effectiveness on the global stage We hope this paper will serve as a resource for charities foundations and policymakers as they seek to understand the impacts that counterterrorism measures have on charities and as they look to develop more equitable policies that protect the inherent rights of charities and the people the organizations serve Download the full paper Download specific sections of the paper Cover materials Executive Summary and Introduction Chapter 1 Overly Harsh Counterterrorism Laws Chapter 2 The Continuously Expanding Interpretation of What Is Prohibited Chapter 3 Lack of Appeal and Due Process Rights Leaves Charities and Foundations Open to Mistake and Abuse Chapter 4 A Solution in Search of a Problem Flawed Assumptions about the Role of Charities and Foundations Chapter 5 Flawed Quasi Mandatory Federal Guidance Has Negative Effects on Charities and Foundations Chapter 6 Counterterrorism Laws Create Barriers for International Philanthropy and Programs Chapter 7 The Mysterious Fate of Frozen Charitable Funds Chapter 8 Counterterrorism Measures Used to Limit Dissent and Public Debate

    Original URL path: http://www.charityandsecurity.org/studies/Collateral_Damage (2016-02-16)
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  • CSN Letter to National Security Council Asks for Humanitarian, Peacebuilding Focus in Civil Society Review | Charity & Security Network
    spaces for civil society to operate in accordance with international law The regulatory review required by the Presidential Memorandum creates an opportunity to lead by example states the August 4 letter to Laura Schulz Director for Global Engagement at NSC Members of the Charity Security Network are concerned that a number of current U S rules including sanctions programs and the prohibition on the material support of terrorism impede or prohibit activities of legitimate NPOs in their efforts to provide humanitarian assistance engage in peacebuilding defend human rights and provide support to local civil society that also work in these areas the letter states The letter notes that these rules were built around the early post 9 11 emergency response and take a one size fits all approach Now 14 years later a more finely tuned and targeted approach to preventing support of terrorism has emerged that is not yet incorporated into U S law the letter asserts This new approach can be seen in the Financial Action Task Force s newly revised Best Practices Paper on Combatting the Abuse of Nonprofit Organizations for example The letter to the NSC asks that in conducting the civil society review agencies consider a number of questions including Are there guidelines for considering humanitarian development peacebuilding or other NPO activities If so what are they What steps can Treasury take to give NPOs it deems to be abused by terrorists an opportunity to solve problems What process does Treasury have for protecting the frozen charitable funds for charitable use What criteria does the State Dept use in the foreign policy review of NPO license applications and What process with USAID use to exempt organizations form the Partner Vetting System when collection of the required information would create safety problems for NPO staff on

    Original URL path: http://www.charityandsecurity.org/CSN_Letter_NSC_Asks_for_Humanitarian_Peacebuilding_Focus (2016-02-16)
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