Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697649241705.pdf (Bahamas)
Non-Profit Organization (NPO) RISK ASSESSMENT QUESTIONNAIRE TO ASSIST IN DEVELOPING A RISK BASED APPROACH TO SUPERVISION AND MONITORING OF THE NPO SECTOR IN THE BAHAMAS This questionnaire is designed to assist authorities in developing a risk based approach to the supervision and monitoring of the NPO Sector within The Bahamas and to ensure that the sector is not abused for terrorist financing.
Additionally, this questionnaire seeks to obtain information on the nature of operations, administration, structure, purpose, activities and procedures in order to determine any money laundering, terrorist financing and proliferation financing risks to which an NPO might be exposed.

Please complete each section and indicate “N/A” where a question does not apply.

Additional paper (clearly marking the particular question) may be used if necessary.
PART 1 - NPO Information Name of NPO: Address of Main Office or Place of Operation in The Bahamas: Mailing Address: Contact Person: Business Telephone: Business Fax: Business Email: Website: PART 2 - Name and contact information of the Controller(s)*: Name: Phone Contact: E-mail: (Please use a separate paper to include information on other Controllers*) (Work/Home) (Last) (First) (Mobile) PART 3 – General Information on NPO Have you submitted the Non-Profit Organization application form to the Registrar General’s Department?
Does the NPO operate at more than one office/location within The Bahamas?

YES YES NO NO Which of the following objects do you promote?

(you can tick more than one box) How long have you been licensed/incorporated?

Do you file a register of Officers and Directors with the Registrar General’s Department?

If you answered yes to the above question, how often do you file the register of Officers and Directors with the Registrar General’s Department?
Religious Charitable Educational Scientific Historical Fraternal Literary Sporting Artistic Other (specify 1 – 3 Years 3 – 5 Years 5 – 10 Years 10 Years and above Not Licensed/ Incorporated YES Annually Do you have a business license?

Do you have a Registered Agent?

If you answered yes to the above question is your Registered Agent regulated by one of the Financial services regulators i.e.

Securities Commission, Compliance Commission, Central Bank of The Bahamas or Insurance Commission?
Does the NPO have a parent body or is affiliated with any other NPO (local or international)?

YES Occasionally Only when a certificate of Good Standing is needed YES YES YES NO NO NO NO NO If you answered ‘YES’ to the above question, provide the names, addresses, purposes and activities of those NPOs.

NAME ADDRESS PURPOSE/ACTIVITY Do you receive donations?

If you answered yes to the above question, are your donors known to you or anonymous?
PART 4 - NPO Banking/Accounting Information Does the NPO utilize a Bahamian or other jurisdiction’s regulated financial institution to facilitate its operations (payment of salaries or disbursements) ?

If no, please explain the method of settling expenses and disbursement and receiving donations: What is your annual turnover?

What was the NPO’s annual inflow, outflow and asset size for the last four (4) years?
YEAR ANNUAL INFLOW ANNUAL OUTFLOW NO YES YES NO YES & NO YES NO < $10,000 $10,000 - $50,000 $50,001 - $100,000 > $100,000 ASSET SIZE % OF ANNUAL INCOME What percentages of last year’s receipts were derived from the following methods of payment (Please provide and annual estimate of the percentage of payments received in each category in the Table below) TYPE OF PAYMENT CASH CHEQUE CREDIT CARD DEBIT CARD WIRE TRANSFER MONEY REMITTANCE STANDING ORDERS VIRTUAL ASSETS GIFTS OR DONATIONS What is the estimated value of outflows and inflows in the last fiscal year sent to or received from foreign jurisdiction(s): Outflows: Inflows: Briefly explain how payments are verified by the NPO: Please indicate in order of priority below, the top three (3) primary sources of income (e.g.
Government subventions, donations, membership dues, etc.

): No.

1.

PRIMARY SOURCE OF INCOME % OF PRIMARY SOURCE 2.

3.

PART 5 - NPO Staff and/or Volunteers Indicate the number of staff members and/or volunteers of the NPO (please provide organizational chart, if any) STAFF MEMBERS: What is the average period of employment?

(years and/or months): What is the process for recruiting?
VOLUNTEERS: PART 6 (A) NPO Compliance Policies and Procedures Has the NPO developed or implemented compliance policies and procedures?

Identify conduct which may involve one or more of the following identified risks NO.

IDENTIFIED RISK (SEC.2 OF PROCEEDS OF CRIME ACT, 2018) Corruption (e.g.

bribery, extortion, misconduct of public officer committed by or on behalf of a public officer) 1.

YES NO YES NO 2.

3.

4.

5.

6.

Cybercrime (any criminal activity using a computer.
e.g., fraud, stealing identities, violating privacy) Human Trafficking (see sec.2 of the Proceeds of Crime Act, 2018) Money Laundering (see sec.
2 of the Proceeds of Crime Act, 2018) Financing of proliferation and weapons of Mass destruction (see FIRST SCHEDULE of the Anti-Terrorism Act (Amendment), 2019) Terrorism or financing of terrorism (see sec.2 of the Anti-Terrorism Act, 2018) Please note that all Bahamas laws can be accessed online at: http://law.bahamas.gov.bs Has your NPO conducted transactions within the last 12 months with any of the following?
[ ] members, individuals or companies based in any of the countries listed by the United Nations as Terrorist Countries?

(see list on the Registrar General’s website http://rgd.bahamas.gov.bs/rgd [ ] individuals or other persons who are politically exposed persons (PEPS)?

(see sec.

2 of the Proceeds of Crime Act, 2018) If you selected any option in the above, which countries were involved and how many transactions were conducted with each country?
Please also indicate the number of PEPs with whom transactions were conducted: Does your NPO cross-reference the names of staff, donors or volunteers with any list of designated individuals or entities on the UN Consolidated Sanctions List?

YES [ ] NO [ ] If YES, state which lists were checked: How often are transaction records reviewed for suspicious patterns of activity?

Fortnightly [ ] Quarterly [ ] Bi-annually [ ] Annually [ ] What identification information does the NPO collect from donors?
(you can tick more than one) Full name Proof of address Date of Birth Nationality Occupational Income (where applicable) Has the organization conducted Enhanced Due Diligence (EDD) on any donor or volunteer within the last 12 months?

If YES, please provide the category of members and how many in each category (e.g.

foreign members, PEPS) Address Phone Place of Birth Nature and Place of Business/Occupation (Where applicable) Other (please specify) YES NO Who in the NPO is responsible for conducting EDD?
To whom do staff/volunteers refer unusual transactions for approval before they are accepted?

Who ensures that staff/volunteers is/are aware that they must not disclose to any member that they have or intend to report a suspicion to the Compliance Officer (if any) or the Financial Intelligence Unit?

(C) Record Keeping Describe any system which the NPO has implemented to record and/or monitor transactions?
What system does your NPO use for storing information on donors identification information or transactions?

(e.g.

electronic or manual) Please provide details.

For how long is the information kept?

(D) Reporting Briefly describe the systems developed and implemented by your NPO to identify and report transactions suspected to be related to money laundering, financing of terrorism or proliferation financing.
How many cash, donation or gift transactions (receipt or payment) of $75,000.00 and over were conducted within the last 12 months?

($75,000.00 refers to one transaction or two or more transactions together which total $75,000.00) the compliance policies Are Directors/Controller/Senior Management?

If YES, what is the approved date?

How frequently are board meetings held?


(Please tick) Weekly Monthly Quarterly Bi-annually Annually and procedures the Board of approved by YES NO Are Minutes of Board meetings kept?

YES NO ATTENDED?

SESSIONS NPO AML/CFT Training Has your NPO taken the Orientation Training of AML/CFT offered by the Compliance Unit, Office of the Attorney-General?

If YES, which of the following sessions were attended?
TRAINING FATF Recommendation 8 Overview of CFATF Mutual Evaluation Findings on The Bahamas The Non-Profit Organisations Act, 2019 and its Amendments (Statutory Guidance for existing and new NPOs) Compliance with Recommendation 8 United Nations Security Council Resolutions/Sanctions Lists The Anti-Terrorism Act The Role of Civil Society NPO Risk Assessment NPO Compliance Tool Kit Who received the NPO Orientation Training?

(e.g.
(e.g.

controller(s), staff or volunteers of the NPO) What other related training have been received by the controller(s), staff or volunteers of the NPO?

Please provide date and details of training.
Date: _________________________________ Name of Controller: ________________________________ Signature:________________________________________ * Under section 2 of the Non-Profit Organisations Act, 2019 a “controller” means — (a) a trustee of a trust, where the non-profit organisation is established as a trust;(b) a director of a company, where the non-profit organisation is established as a company; (c) a general partner of a partnership, where the non-profit organisation is established as a partnership; (d) a person or slate of officers or trustees responsible for all aspects of management and administration of an unincorporated association, where the non-profit organization is established as an unincorporated association; (e) a member of a corporation, where the non-profit organization is established as an entity incorporated by statute; (f) a founder of a foundation, where the non-profit organization is established as a foundation; or (g) any person not specified in paragraphs (a), (b), (c), (d), (e) or(f) where the non-profit organisation is established by that person;