Comment from Charity & Security Network (C&SN)

Summary: The Charity & Security Network (C&SN) supports the proposed rules to modernize the Bank Secrecy Act but argues that the final rules must include specific protections to prevent "de-risking" and the exclusion of nonprofit organizations (NPOs) from the financial system. They advocate for a risk-based approach that distinguishes lawful humanitarian and advocacy activities from illicit finance, specifically requesting that AI tools and independent audits do not automate or incentivize the unfair restriction of NPO access to banking services.