amp CaLP scoping study on Risks and Financial Management DATE 7 November 2019 LOCATION Global FSC webinar SPEAKERS CaLP Alice Golay Risks and CVA CVA 68 from 2016 to 2018 ID: 912006
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Slide1
Initiatives on Risk and CVA & CaLP scoping study on Risks and Financial Management
DATE:
7 November 2019
LOCATION:
Global FSC webinar
SPEAKERS:
CaLP
,
Alice Golay
Slide2Risks and CVA
CVA
68%
from 2016 to 2018 now at 4.7 billion = time to focus on QUALITY Risks as one of the biggest barriers to effective and expanded use of CVA (State of the World Cash Report 2018) Incl. broader risks in humanitarian action that have specific implications for CVA. Working group on Risk under the cash workstream of the Grand Bargain, co-led by WFP and CaLP. CaLP as a membership network aims to help actors understand and mitigate risks, facilitate an environment of openness for experience sharing and ensure collaboration around risks.
Global Food Security ClusterWebinar on RISKS and CVA7 November 2019
Slide3Overview - Ongoing initiatives
October - December 2019
Global Food Security Cluster
Webinar on RISKS and CVA7 November 2019
Webinar: Data sharing in CVA, ethics, ownership and privacy
Learning Event: Risk Management, Douala
Webinar: Organizational readiness for data management
.
Learning Event: Risks and CVA with local NGOs of North-West Syria, Gaziantep
29 Oct
7 Nov
Webinar Global FSC: Risks and CVA
26 Nov
Learning Event: Risk and CVA, with INGOs working inside Syria,
Beirut or Amman tbc
Learning Event: Putting responsible beneficiaries’ data protection at the heart of our work, Dakar
Cash Week event:
CT Financing and Anti Money Laundering, Data Responsibility and Protection in CVA, London,
here
.
20 Nov
Webinar: Biometrics, risks and benefits, Middle East
Guest blogging
e.g. Linda Raftree on data responsibility,more coming
Ongoing
16 Oct
31 Oct – 1 Nov
21 Nov
27 Nov
4 Dec
Slide4CaLP
Scoping study on Risks & Financial Management
Global Food Security Cluster
Webinar on RISKS and CVA7 November 2019Study’s focus Existing legal frameworks don’t target humanitarian action or CVA, but can have significant consequences.Many humanitarian organizations are lacking capacity and guidance to confidently manage these risks.
CaLP members have demonstrated possibility to influence regulators but it does take so much time and efforts. Anti-Money Laundering
Counter-Terrorism Financing
Three specific challenges:
Transfers of funds to country of operations.
Identification of in-country service providers.
Beneficiary identification and data security.
CaLP
Scoping study on Risks & Financial Management
Global Food Security Cluster
Webinar on RISKS and CVA7 November 20191. Transfers to country of operationsCurrent reality: “Cooling effect” at national levelReputational and compliance risk burden for FSPs in country, in addition to national legislation. Humanitarian organizations less attractive as clients.
FSPs protecting themselves from regulatory penalties.Steps that can be undertaken by CVA actors
Financial Action Task Force recommends a
risk-based approach.
Prepare banking relations in regions of potential future operations.
Collaborate, propose scale, share bank facilities, negotiate as group, etc.
Slide6CaLP
Scoping study on Risks & Financial Management
Global Food Security Cluster
Webinar on RISKS and CVA7 November 20192. Identification of in-country service providers:Steps that can be taken by CVA actorsAssess and identify capable and willing FSPs.Improve own understanding of AML/CTF and sanctions regulations.
Adopt a Know your Business (KYB) approach. CWG develops strong relationship with central bank.AML/CTF regulations apply when FSPs are contracted to deliver CVA to recipients
FSP
unwilling
to take humanitarian organizations as clients
Weighing the compliance risk.
De-risking, deterrents.
Risk varies for FSPs at national level e.g. banks under more scrutiny than Hawalas or MNOs.
Slide7CaLP
Scoping study on Risks & Financial Management
Global Food Security Cluster
Webinar on RISKS and CVA7 November 20193. Beneficiaries identification and data securityCurrent realityEC AMLD-5 - Transfers of 50 USD and over Screening of individual beneficiaries against sanction lists:
Targeting/eligibility of beneficiaries so far considered by Humanitarian actors as sufficient for CTF. Screening often not carried out + rarely considered an effective mitigation measure on its own. Would be a red line for some organizations: refusing grants.Has not yet emerged as an issue but could be a future worst-case scenario.
Organization required to know the recipient and the likely use of funds
Slide8CaLP
Scoping study on Risks & Financial Management
Global Food Security Cluster
Webinar on RISKS and CVA7 November 2019Conclusions & Food for thoughtBetter understanding of Governments’ regulations on FSPs. Humanitarian actors to increase influence on FSPs and engage with regulators.Shared information on risk registers in relevant coordination bodies.
CVA/humanitarian actors to understand what affects financial flows, find the right partnerships.Donor governments to provide clear guidance, define standards.Humanitarian actors to unpack what the real risks are and increase donors’ comprehension of control/oversight in place.
less risk aversion.
less extensive donor/regulators
requests on CVA.
joint mitigation measures.
Working more on the country/national level
And more globally...
better equipped.
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