Reports

Human Security Collective (HSC) and European Center for Not-for-Profit Law (ECNL)
2018
At the Intersection of Security and Regulation: Understanding the Drivers of ‘De-Risking’ and the Impact on Civil Society Organizations
Human Security Collective and ECNL
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…Learn More
Charity & Security Network (C&SN)
February 2021
Financial Access for U.S. Nonprofits: How Federal Regulatory Obstacles Hinder Nonprofit Work Around the World
This report highlights the significant financial access barriers faced by U.S.-based international charities due to de-risking practices by banks. Since the post-9/11 expansion of AML/CFT regulations, two-thirds of nonprofits surveyed report encountering delays, documentation burdens, increased fees, and account closures. These restrictions, driven by regulatory fears and inconsistent enforcement, often force charities into less transparent…Learn More
Jonathan Benthall
Fall 2024
Toward a Fair Deal for Muslim-Led Charities
Muslim Humanitarianism Review (MHR) Journal
This commentary compares the experiences of Muslim-led charities in the US, UK, France, and Canada. It discusses the evolution of policies after 9/11 and how restrictions have expanded to other sectors.Learn More
Institute for Social Policy and Understanding (ISPU)
2022
Banking While Muslim
The ISPU produced data on the banking challenges faced by Muslims in the U.S. in 2022.Learn More
IFC.org
November 2016
DE-RISKING BY BANKS IN EMERGING MARKETS – EFFECTS AND RESPONSES FOR TRADE.
IFC report shows that heightened post-crisis regulatory requirements, including higher capital buffers under Basel III and stricter AML/CFT/KYC rules, have increased banks' compliance costs and risk exposure. This has led to "de-risking," where banks terminate or curtail correspondent banking relationships. The report highlights that this disproportionately harms smaller economies (notably in Africa, the Caribbean, and…Learn More
University of Toronto
2021
Under Layered Suspicion
This report details how Muslim charities in Canada faced disproportionate audits and financial scrutiny.Learn More
Gordon, S.; Robinson, A.; Goulding, H.; Mahyub, R.
August 2018
The impact of bank de-risking on the humanitarian response to the Syrian crisis
HPG Working Paper
A report suggests that humanitarian organisations operating in Syria face significant challenges in moving money into the country. The principal challenges are with: moving money through the correspondent, banking system, the consequences of banks closing accounts; increased and inconsistent due diligence, requirements; increased transaction costs associated with international financial transactions; the interaction of CTF legislation…Learn More
Sherine El Taraboulsi-McCarthy
Feb 2023
Whose risk? Bank de-risking and the politics of interpretation and vulnerability in the Middle East and North Africa
International Committee of the Red Cross (ICRC)
This analysis, published by the ICRC, examines how Counter-Terrorism Financing (CTF) measures in conflict zones such as Somalia, Syria, and Yemen hinder the delivery of humanitarian aid.Learn More
Tracey Durner and Liat Shetret
November 2015
Understanding Bank De-risking and its Effects on Financial Inclusion
Oxfam & Global Center
This report was one of the first comprehensive looks at de-risking. It defines de-risking as banks exiting relationships with and closing accounts of clients considered high risk. The report notes that this practice impacts money service businesses, foreign embassies, nonprofits, and correspondent banks in the US, UK, and Australia.Learn More
Midaynta Community Services/Munk School
2022
Understanding Canadian-Somali Remittance Flows
This report documents instances of Canadian banks closing numerous Somali Money Service Business (MSB) accounts, which disrupted remittance flows and highlighted a lack of data regarding de-risking practices.Learn More