KYB for Non-Profits/NGOs in High-Risk Jurisdictions
Curious if anyone has insights or best practices for navigating KYB when dealing with non-profit organizations or NGOs operating in jurisdictions flagged as high-risk for financial crime. The layered ownership and often complex funding streams can make standard beneficial ownership identification extremely difficult, even with enhanced due diligence. What are some effective strategies to manage this without outright de-risking and potentially excluding legitimate entities?
That's a tough one. We've found that focusing on the programmatic activities and their funding flows, rather than solely on ownership structure, can sometimes provide a clearer picture of beneficial impact and control, even if it doesn't fit the traditional KYB mold perfectly. How do others handle verifying the actual use of funds in these scenarios?