The European Center For Not-for-Profit Law (ECNL) has seen that civil society organisations (CSOs) increasingly encounter difficulties in opening and maintaining bank accounts, due to the detrimental effects of legislation in regard of anti-money laundering (AML) and combatting terrorist financiering (CFT), requiring banks to carry out expensive customer due diligence. This is caused by incorrect risk assessments by the authorities on the nonprofit and by risk-averse behaviour of banks (‘de-risking’).

ECNL together with PILnet has launched a series of overviews of banking conditions in European countries.  ECNL writes on its website:

These overviews aim to support CSOs that wish to open a bank account in the selected countries or compare conditions between these countries. It aims to help CSOs navigate through the organizational banking requirements which are becoming increasingly complex. The countries and issues in these overviews have been selected based on requests lodged to our organizations by national and international partners.

New profiles will be uploaded on a rolling basis.

Our overviews provide information on the following issues:

1. REQUIREMENTS FOR OPENING AN ORGANIZATIONAL BANK ACCOUNT, INCLUDING:

• Whether physical presence of a legal representative is required;
• Specific requirements related to organization’s internal operation, such min./max. annual turnover, nationality of statutory representatives etc.;
• Who is authorized to open organizational bank account;
• General information about the process, including timelines.

2. BANKING ACTIVITIES, INCLUDING:

• Customer due diligence requirements;
• Monitoring criteria for suspicious transactions;
• Limitations to bank transactions and transfers to certain jurisdictions.

3. OBLIGATIONS AND REPORTING REQUIREMENTS:

• Reporting to regulatory and public authorities by banks;
• Protection of privacy of clients’ information;
• Reporting to public authorities about civil society banking.