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 labs who conduct compliance and back-tracing for all crypto donations.”
Is the idea that such controls, had they been implemented in the past, would have prevented you from accepting Delo’s donations?
Also, I am curious to see CEA’s cost-benefit analysis behind this decision. Naively this seems like incurring a cost (staff time, consultant fees, lawyer fees, annoy donors) in order to reduce a benefit (donations). Based on my cursory research (talking to a lawyer and reading this) I couldn’t work out if this was actually legally required given CEA’s situation, though it does seem to be reasonably common.
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 labs who conduct compliance and back-tracing for all crypto donations.”
Is the idea that such controls, had they been implemented in the past, would have prevented you from accepting Delo’s donations?
Also, I am curious to see CEA’s cost-benefit analysis behind this decision. Naively this seems like incurring a cost (staff time, consultant fees, lawyer fees, annoy donors) in order to reduce a benefit (donations). Based on my cursory research (talking to a lawyer and reading this) I couldn’t work out if this was actually legally required given CEA’s situation, though it does seem to be reasonably common.
I am checking with operations staff about this.