This joint 2018 report by HSC and ECNL investigates the impact of post-9/11 AML/CFT frameworks on nonprofit access to banking, especially among smaller NGOs in Brazil, Mexico, and Ireland. It finds that regulatory overreach, lack of clear guidance, and inconsistent application of rules have led banks to exit NPO relationships—a phenomenon known as de-risking. The report recommends coordinated multi-stakeholder reform, better examiner training, clearer FATF guidance, donor-funded compliance support for small CSOs, fintech adoption, and accessible grievance mechanisms to balance security goals with civil society sustainability.