6.4.6 Requirements for Non-Profit Organisations

Effective from 13/7/2023

Non-Profit Organisations (NPOs) can often pose increased risks in regard to money laundering, the financing of terrorism, and the financing of illegal organisations. As part of an effective risk-based approach to AML/CFT, FIs that enter into or maintain Business Relationships with NPOs should take adequate CDD measures that are commensurate with the risks involved (see Sections 6.3, Customer Due Diligence (CDD) Measures and 6.4, Enhanced Due Diligence (EDD) Measures). Examples of measures that FIs should consider include, but are not limited to:

•	Ensuring that the NPO is properly licensed or registered; in particular, when opening any accounts for Non-Profit Organisations, FIs licensed by the Central Bank must obtain an original signed letter from the Ministry of Community Development for opening accounts to collect donations and an authorization from the UAE Red Crescent for conducting financial transfers out of the UAE through some of these accounts;
•	Obtaining information about and assessing the adequacy of the NPO’s AML/CFT policies, procedures and controls;
•	Obtaining sufficient information about the NPO’s legal, regulatory and supervisory status, including requirements relating to regulatory disclosure, accounting, financial reporting and audit (especially where community/social or religious/cultural organisations are involved, and when those organisations are based, or have significant operations, in jurisdictions that are unfamiliar or in which transparency or access to information may be limited for any reason);
•	Obtaining sufficient information about the NPO’s ownership and management structure (including taking into consideration the possibility of PEP involvement); the nature and scope of its activities; the nature of its donor base, as well as of that of the beneficiaries of its activities and programmes; and the geographic areas in which it operates, so as to be in a position to identify, assess, and manage or mitigate the associated ML/FT risks;
•	Performing thorough background checks (including but not limited to the use of internet searches, public databases, or subscription information aggregation services) on the NPO’s key persons, such as senior management, branch or field managers, major donors and major beneficiaries, to screen for possible matches with targeted and other international financial sanctions lists, indications of criminal activity (including financial crime), or other adverse information.

FIs that enter into or maintain relationships with NPOs should also use a risk-based approach to determine the appropriate internal AML/CFT policies, procedures and controls the FIs implement in relation to the risk assessment, risk classification, and the type and extent of CDD they perform on NPOs. The policies and procedures that FIs apply should be reasonable and proportionate to the risks involved, and should be adequately documented, senior management approved, and communicated to the relevant employees of the organisation.