Humanitarian operations preserved amid terror-financing designation threat
Situation:
A large international humanitarian relief charity faced a threatened OFAC designation based on allegations of terrorist financing. The threat jeopardized the organization’s operations, donor relationships, banking access, and ability to deliver aid.
The matter required coordinated pre-designation advocacy, stronger counterterrorist-financing and anti-money laundering procedures, responses to adverse media reporting, and resolution of charitable transfers frozen by intermediary banks.
Stakes:
A designation could have frozen the charity’s assets worldwide, severed banking relationships, and triggered mandatory compliance action by financial institutions, donors, and counterparties. The organization faced the potential collapse of its international aid network and a complete halt to humanitarian operations.
The consequences extended beyond the charity itself to communities that depended on its programs for essential assistance.
Result:
Ferrari & Associates developed and executed a coordinated pre-designation defense. The firm prepared a request for stay of designation, designed counterterrorist-financing and anti-money laundering procedures tailored to the organization’s operations, and submitted detailed factual responses addressing the allegations and adverse media reports.
The firm also managed direct engagement with OFAC’s Office of Global Targeting and coordinated the release of charitable transfers held by intermediary banks. The advocacy and documented compliance improvements prevented the threatened designation, allowing the charity to resume operations with stronger controls and restored banking relationships.
