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organizations from making international grants. However, the Treasury
Department rejected many of the suggestions included in the comments.

The suggested anti-terrorist procedures require collecting extensive
information about the potential recipient, and demonstrating that the grantor has
(1) collected certain basic information about a grantee; (2) conducted basic vetting
of grantees, including a reasonable search of publicly available information to
determine whether the foreign recipient organization is or has been suspected of
activity relating to terrorism, including terrorist financing or other support, and to
determine that the grantee and its key staff are not on the OFAC list or subject to
OFAC sanctions, and (3) conducted basic vetting of its own key employees, including
a reasonable search of publicly available sources to determine whether they are
suspected of activities relating to terrorism or are subject to OFAC sanctions.
Furthermore, if a charity’s vetting practice leads to a finding that any of its own key
employees, any of its grantees, or any of the key employees of grantees is
suspected of terrorism activities, the Voluntary Treasury Guidelines direct the
charity to take certain actions.

CHAPTER 44. Best Practices

At the present time, grant-makers do not possess any “official” guidance from
the Treasury Department to aid in developing compliance plans and procedures
that will satisfy the requirements of Executive Order 13224, the USA Patriot Act, and
other laws. As discussed above, the Voluntary Treasury Guidelines are simply that:
voluntary. Moreover, these guidelines can generate significant burdens on grant-
makers, especially smaller organizations, and are expensive to carry out. Finally,
there is no assurance that a grant-maker complying with the Voluntary Treasury
Guidelines will avoid violating the law.

WASHINGTON NONPROFIT HANDBOOK -132- 2018