Bank De-Risking of NonProfit Clients: A Business & Human Rights Perspective

Human Security Collective & ABN AMRO

HSC and ABN AMRO  will convene a conversation on the financial exclusion being experienced by NPOs and ways of moving forward to solve it.

In the wake of stricter anti-money laundering and counter-terrorism financing (AML/CTF) legislation, 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), ABN AMRO and Dentons Netherlands. 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. 
Program:
•	 Introduction to de-risking of NPO’s by Thalia Malmberg of Human Security Collective
•	The impact of de-risking on the work of NPO’s and their beneficiaries by Riad Sabbagh of the Norwegian Refugee Council and Tahir Iqbal of Islamic Relief Worldwide
•	A business and human rights perspective by Ruben Zandvliet of ABN AMRO
•	Way forward with Lia van Broekhoven of Human Security Collective
•	Q &amp; A
About the Speakers:
Thalia Malmberg is a Program Manager at Human Security Collective, working on issues related to de-risking and the effects of countering terrorism financing measures on civil society. She previously worked for the Women Peacemakers Program, researching the impact of these measures on women’s organizations. 
Riad Sabbagh is the Policy and Advocacy Advisor for Norwegian Refugee Council in Damascus, Syria. He has extensive previous past experience in sanctions and impacts of sanctions on Syria with different organizations. He also headed the Sanctions project at the United Nations Economic and Social Commission for Western Asia – National Agenda for the Future of Syria Program – UNOPS).
Tahir Iqbal is currently the Head of Treasury, Finance and Services at Islamic Relief Worldwide. He is responsible for defining and maintaining a robust banking and treasury policy for Islamic Relief, and specifically oversees Islamic Relief’s banking and foreign currency relationships. Since joining Islamic Relief Worldwide over 14 years ago, Tahir, a qualified Chartered Accountant, has become a leader and reference point across Islamic Relief Worldwide and the Islamic Relief family - educating program managers on risk management and empowering and building the capacity of Islamic Relief field and partner offices to manage funds effectively and efficiently in order to meet international standards. Additionally, he leads the Anti-Aid Diversion and Financia l Crime team, which is key to the implementation of Islamic Relief’s financial crime policies and KYC activities. 
Ruben Zandvliet is a Business and Human Rights Advisor at ABN AMRO, where he works on the implementation of the UN Guiding Principles and the bank’s human rights reporting efforts. He is involved in the conversation around upcoming legislation on responsible business conduct and represents the bank in many external fora. Ruben has a PhD in international trade and investment law. His dissertation focused on the way economic law constrains and enables labour regulation. He also worked in the Dutch Parliament as a policy officer on responsible business conduct and corporate governance.
Lia van Broekhoven is co-founder and executive director of Human Security Collective. Prior to founding HSC Lia had worked since 1989 as researcher, policy advisor and development practitioner with UNFPA, FAO, Natural Resources Institute, World Bank and others. As policy advisor at the Dutch INGO Cordaid, she set up an initiative in 2007 that strengthened the engagement of civil society with governments and international organizations on counter-terrorism (financing) related issues, highlighting the importance of the operational and political space for civil society for furthering human rights, conflict prevention, humanitarian assistance and development. She is co-chair of the Global Nonprofit Coalition on the FATF/Financial Action Task Force and holds a seat for the Coalition on the FATF Private Sector Consultative Forum.



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Bank De-Risking of NonProfit Clients: A Business & Human Rights Perspective

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