The 6 page note [PDF] is drawn from the AIC's Money laundering and terrorism risks to Australian non-profit organisations by Bricknell, McCusker, Chadwick & Rees, not yet available on the Institute's site.
Bricknell comments that -
The manner in which terrorist organisations finance their activities became a policy focal point after the terrorist attacks of 11 September 2001. Non-profit organisations, and charities in particular, were identified as potentially significant contributors to terrorism financing. This premise was based on known links between charitable giving and prominent terrorist groups, and the vulnerabilities of the non-profit sector to misuse.
Money laundering and terrorism financing (ML/TF) risks to the Australian non-profit sector are thought to be low. However, the impact of such misuse is inevitably high. One of the underlying premises in combating non-profit misuse has been the application of a response proportionate to risk. Australia has based its response on education, sector outreach and peak body codes of conduct, alongside more conventional forms of regulatory control.
This paper examines vulnerabilities to ML/TF misuse and the publicly available evidence for actual misuse. It is suggested that the Australian response could incorporate a more uniform commitment from the sector to adopting risk-based strategies, with government providing education for the sector that is based on the identification of specific points of vulnerability.