AT THE INTERSECTION OF SECURITY AND REGULATION: UNDERSTANDING THE DRIVERS OF ‘DE-RISKING’ AND THE IMPACT ON CIVIL SOCIETY ORGANIZATIONS

Non-profit organizations (NPOs) around the world are impacted by issues of financial access – inordinate delays in cash transfers, onerous due-diligence requirements, inability to open bank accounts and arbitrary closure of bank accounts – collectively classed as ‘de-risking’ activities by financial institutions. This study examines the drivers of this de-risking, situating it at the intersection of frameworks for security and regulation. It looks at how global regulations on money laundering and terrorism financing, for instance, permeate policymaking, influencing institutions (perversely, at times) and negatively impacting humanitarian and development work. By delving into the practices and perspectives of relevant stakeholders –  NPOs, financial institutions, governments, regulators and international organizations – the study unpicks the mechanisms of governance and accountability involved in and through the chain of decision-making, underscoring the policy incoherence that is manifest along the way. The three country contexts chosen for the research – Brazil, Mexico and Ireland – help amplify the complexity of the issue and the potential search for solutions. Ongoing remedial measures addressing the financial exclusion of NPOs are highlighted and potential remedies that could challenge the current practice of de-risking are explored in detail.