• Financial institutions are required by Section 34 of the Prevention of Terrorism Act 2005 to report suspicious transactions relating to the financing of terrorism. 
• Financing of terrorism activities tend to be more subtle to detect than those that are solely money laundering. 
• This is particularly true of Non-Profit Organizations (NPOs), which are legal entities or organizations that primarily engage in raising or disbursing funds for purposes such as charitable, religious, cultural, educational, social or fraternal purposes, or for the carrying out of other types of “good works”.

• Red flags are particular behaviours, patterns and / or situations that present themselves in transactions of donors or beneficiaries that could be linked to illegal activities.

• Uncommon and sizeable one-off donations are received from anonymous or suspicious sources.
• NPO receives a series of small donations from sources that are anonymous or untraceable.
• Donations made in a foreign currency or foreign sources where the AML/CFT financial regulation, or legal framework is not robust or effective. 
• Payments are received from a recognized donor but through an unfamiliar party.
• Donations received from unknown or anonymous bodies.

• Beneficiary expects a favour or advantage from an NPO based on monetary contribution to their cause.
• Services provided to a large number of beneficiaries which allow for easy concealment of suspicious or questionable beneficiaries.
• Beneficiary(s) attempts to persuade a NPO to include them into their distribution and aid lists due to kickbacks and bribes offered. 
• Lists of beneficiaries contain multiple manual corrections, multiple names may appear, may contain more family members.

• Invoices and paperwork have been tampered with, altered in crucial aspects with handwritten amendments.
• Inventory shortages.
• The project is vague or lacks adequate financial or technical details.
• Missing key documents or only copies can be reproduced.
• Lack of evidence to show fair and transparent tendering or procurement procedures.
• Invoices and papers recording a higher cost for goods or services than expected or agreed.
• Signature confirming receipt or payment are missing or the invoices unsigned or undated.
• Receipts have been signed and dated a long time after the good or services should have been delivered.
• Repeated excuses of system crashing, losing records or paperwork.
• Discrepancies between budgeted needs and payments requested.
• Requests for payments in cash to be made to an unknown third party or other organization. 
• Funds are not being deposited or accounted for.
• Emails from new or unusual email addresses not in the partner’s domain name or from someone who is not a previously agreed contact point.
• Inconsistencies between narrative reports and financial claims and reports.
• NPOs that despite developing projects for high sums of money do not have either the employees or the capacity to execute those projects.

• The structure or nature of the proposed project makes it difficult to identify and verify the partner’s details.
• The project proposal includes delegating work to other unknown partners or newly established organizations.
• Partners request unnecessary or unusual levels of privacy and secrecy.
• Partners request that the NPO uses a specific auditor or accountant.
• The project involves unusual payment methods, requests for cash, or funds to be paid into an account not held in the name of the partner, or in a country where the partner is not based or where the project is not being conducted.
• If the NPO has difficulty contacting the partner at their main address or their telephone numbers are out of service.
• NPOs that open financial products with hardly verifiable personal and/or commercial references, or whose partners or legal representatives are never in the country.

• If a NPO suspects that staff may be living beyond their means or appearing at unusual times.
• Staff carrying out tasks or jobs they should not be, or other unusual staff behaviour or conduct. 
• If staff are affiliated with other NPOs or specified entities.

Please note that the above list of warning signs for the NPO sector serves as a guide and is by no means exhaustive.  Therefore, it is imperative that as an entity within the sector that keen attention is paid to detect and report any unusual or suspicious behaviour and activity. 

All such behaviours and activities should be reported promptly to the Supervisory Authority, ONDCP.