Here’s an update from CEA’s operations team, which has been working on updating our practices for handling donations. This also applies to other organizations that are legally within CEA (80,000 Hours, Giving What We Can, Forethought Foundation, and EA Funds).
“We are working with our lawyers to devise and implement an overarching policy for due diligence on all of our donors and donations going forward.
We’ve engaged a third party who now conducts KYC (know your client) due diligence research on all major donors (>$20K a year).
We have established a working relationship with TRM who conduct compliance and back-tracing for all crypto donations.”
I honestly doubt that this process would have, or should have, flagged anything about SBF. But I can imagine it helping in other cases, and I think it’s important for CEA to actually be following its stated procedures.
I hope that the “overarching policy for due diligence on all of our donors” that was put together post-Delo in 2021 was well designed. But it’s also worth noting Zach has also discussed “increasing the rigor of donor due diligence” in 2023. Maybe the 2023 improvements took the process from good to great. Maybe they suggest that the 2021 policies weren’t very good. It’d be great for the new and improved policy, and how it differs from the previous policy, to be shared (as Zach has suggested it will be) so other orgs can leverage it and to help the entire community understand what specific improvements have been made post-FTX.
As of February 2021:
I honestly doubt that this process would have, or should have, flagged anything about SBF. But I can imagine it helping in other cases, and I think it’s important for CEA to actually be following its stated procedures.
I hope that the “overarching policy for due diligence on all of our donors” that was put together post-Delo in 2021 was well designed. But it’s also worth noting Zach has also discussed “increasing the rigor of donor due diligence” in 2023. Maybe the 2023 improvements took the process from good to great. Maybe they suggest that the 2021 policies weren’t very good. It’d be great for the new and improved policy, and how it differs from the previous policy, to be shared (as Zach has suggested it will be) so other orgs can leverage it and to help the entire community understand what specific improvements have been made post-FTX.