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Terrorist Financing

NPO & Charity Diversion

Funds raised or held by a non-profit or charity are diverted to conflict zones, proscribed groups, or unintended high-risk parties. Indicators include donation washing through legitimate-looking causes and a mismatch between the charity's stated purpose and the geography or nature of its outbound transfers.

Firm typesBank / Credit InstitutionE-Money Institution (EMI)Payment Institution (PI)Money Service Business (MSB)
ProductsCross-Border PaymentsDomestic PaymentsRemittanceE-Money Accounts
CustomersNon-Profit / CharitiesIndividuals
Key terms:

What it is

Funds raised or held by a non-profit or charity are diverted to conflict zones, proscribed groups, or unintended high-risk parties. Indicators include donation washing through legitimate-looking causes and a mismatch between the charity's stated purpose and the geography or nature of its outbound transfers.

Control objective

Detect diversion of charitable or non-profit funds to conflict zones, sanctioned parties, or destinations inconsistent with the organisation's declared charitable purpose.

Data required

  • Registered charitable purpose and stated areas of operation
  • Beneficiary countries and counterparties for outbound transfers
  • Donation inflow patterns (volume, frequency, donor concentration)
  • Onward distribution destinations and field-partner details
  • Charity registration status and governance structure
  • Cash deposit and withdrawal activity
  • Proximity of transfer destinations to conflict or high-risk zones
  • Trustee and signatory information