Human Security Collective (HSC) and Dutch bank ABN AMRO have just launched a new report “Bank De-Risking of Non-Profit Clients: A Business and Human Rights Perspective”, which was prepared by the European Public Interest Law Clinic of New York University Law School in Paris, and which we thought might be of interest to your Civil Society Advisory Group.

Background on the Report:
In the wake of stricter anti-money laundering and counter-terrorism financing (AML/CTF) legislation, nonprofit organizations (NPOs) have suffered disproportionate restrictions on access to financial services. This report “Bank De-Risking of Non-Profit Clients: A Business and Human Rights Perspective” explores decisions made by banks that lead to de-risking. It explains the forms, root causes and consequences of de-risking, the relevant human rights norms and practical actions to allow banks to manage perceived risks of their Non-Profit Organization (NPO) clients whilst respecting human rights. It is intended for a broad audience of banking staff. We hope that it will serve as the basis for cross-functional cooperation within and between banks to better facilitate access to financial services for NPOs. This report has been prepared by the European Public Interest Law Clinic of New York University Law School in Paris, in cooperation with Human Security Collective (HSC) and ABN AMRO.

More precisely, this report is based on the premise that banks’ discretion to de-risk NPOs is limited by their responsibility to respect human rights under the United Nations Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises. Although many banks recognize the UNGPs and the OECD Guidelines as authoritative normative frameworks, implementation has focused mostly on human rights risks that banks are exposed to via their corporate lending, project finance and asset management activities. Better understanding of the human rights risks associated with banks’ own operations is important for those institutions that aspire to fully implement the UNGPs and OECD Guidelines.