Charity News: Use of cash couriers

Cash couriers are those persons who physically transport cash from one jurisdiction to another. In conjunction with the Counter Terrorism unit of the Metropolitan Police, CCEW has published a warning to charities operating internationally against the use of cash couriers as a means of transferring charity funds due to the significant risks involved. Those risks include:

• As cash couriering is known to be used by terrorist and criminal organisations when challenged, if police or ports officers are not satisfied that the sources or end use of the cash cannot be accounted for, it is likely to be seized under the Terrorism Act 2000 or Proceeds of Crime Act 2002 and potentially forfeited on a successful application to the courts.
• Recovering any cash seized in this way is likely to take a significant amount of time, inconvenience and cost, with the potential to result in operational delays and reputational damage.
• Carrying significant amounts of cash makes the courier a target for criminals.
• The difficulty in maintaining an audit trail and adequate records that make it difficult to account for the funds and demonstrate that they have been used for charitable purposes.
• Cash couriers are not regulated, leading to concerns over their quality and reliability.

CCEW’s guidance urges charities to use established, regulated banking systems for transferring charitable funds wherever possible. Failure to do so may be considered to be misconduct and/or mismanagement of the charity if trustees cannot show that they have managed the risks associated with the use of cash couriers effectively. They do acknowledge though that in exceptional circumstances the use of cash couriers is unavoidable, and sets out some of the steps charities should take in order to minimise the risks involved.

Guidance: Regulator renews its message warning charities against the use of cash couriers

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