Médecins Sans Frontières (MSF), also known as Doctors Without Borders, is a humanitarian organization providing medical assistance in conflict zones and countries affected by endemic diseases. While MSF’s core mission is medical, the organization has a crucial finance and accounting function, including a dedicated effort to combat financial crime. This effort often involves interaction, directly or indirectly, with Financial Intelligence Units (FIUs) around the globe.
FIUs are government agencies that collect, analyze, and disseminate financial intelligence to combat money laundering, terrorism financing, and other financial crimes. MSF, as a large international non-profit operating in complex and high-risk environments, has a responsibility to ensure its funds are not used to support illicit activities. This requires implementing robust internal controls and engaging with FIUs to comply with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
MSF’s engagement with FIUs can take several forms. Primarily, MSF implements its own robust due diligence procedures regarding donors and partners. This includes screening for politically exposed persons (PEPs), individuals or entities on sanction lists, and entities involved in high-risk activities. If suspicious activity is detected during this due diligence, MSF may be required to file a Suspicious Activity Report (SAR) with the relevant FIU. This report would detail the nature of the suspicious transaction or activity and provide any supporting information. The FIU would then analyze the report and determine whether further investigation is warranted.
Beyond SAR filing, MSF might also receive inquiries from FIUs. These inquiries could be related to specific transactions or individuals, or they could be part of a broader investigation. MSF is obligated to cooperate with these inquiries and provide any relevant information it possesses, subject to legal and ethical considerations around patient confidentiality and data privacy. This collaboration ensures that MSF is not inadvertently facilitating financial crime and that its funds are used solely for humanitarian purposes.
Furthermore, MSF needs to be aware of the evolving AML/CTF regulations in the various countries where it operates. This includes understanding local reporting requirements, risk profiles, and FIU mandates. A strong compliance program, including regular staff training, is essential for ensuring adherence to these regulations and effective interaction with FIUs.
The relationship between MSF and FIUs is ultimately one of mutual benefit. By cooperating with FIUs, MSF contributes to the global effort to combat financial crime and protect the integrity of the financial system. Simultaneously, MSF safeguards its reputation, ensures the security of its funds, and maintains its ability to provide life-saving medical assistance to those in need, free from interference or complicity with illegal activities.