Jubilee USA submission to the consultation on the Notice of Proposed Rulemaking on Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities

Click here to read this submission on the official consultation website. 

February 14, 2023

Acting Director Himamauli Das
Financial Crimes Enforcement Network (FinCEN)
U.S. Department of Treasury
P.O. Box 39
Vienna, VA 22183

Re: Notice of Proposed Rulemaking on Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities (RIN 1506-AB49/AB59 / Docket Number FINCEN-2021-0005)

Jubilee USA Network appreciates the opportunity to comment on the notice of proposed rulemaking, “Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities.”

We are an alliance of more than 75 US organizations and 750 faith communities working with 50 Jubilee global partners to build an economy that serves, protects and promotes the participation of the most vulnerable. We are concerned with how financial secrecy, corruption and tax evasion are connected to poverty in the United States and abroad. In particular, we have witnessed how anonymous shell companies have facilitated exploitation of vulnerable communities and supported corrupt regimes in the developing world.

The Corporate Transparency Act introduces transparency into otherwise anonymous corporate structures by requiring companies to report their true, “beneficial” owners to a secure directory housed at FinCEN.

We promoted and worked towards passage of this legislation for more than 10 years. During that time we built support with members of Congress, senators and Administrations from both parties. We made this investment because our members consider this legislation essential to: 1) stop ways that human traffickers hide and make profits, 2) prevent the exploitation of vulnerable communities in the United States through Medicaid and Medicare fraud, 3) curb the theft of development and debt relief aid, 4) reveal theft from corrupt foreign governments of public monies, and 5) help raise revenue in the developing world.

Our members have an interest in seeing strong, effective rules that maximize the law’s potential to contribute to such purposes. We commented in the FinCEN rulemaking process leading to the final rule on Beneficial Ownership Information Reporting Requirements and appreciate that many of our comments were considered and reflected.

The same spirit informs our formulation of responses to the current call for comments.

The CTA includes a mandate that the database provide “highly useful” information to law enforcement. We believe that law enforcement - federal, state, local, tribal, and, in appropriate cases, foreign – and financial institutions with anti-money laundering obligations, database auditors, and other authorized users should have simple, comprehensive, and timely access to this information. Only this level of access to the directorate of beneficial ownership information will meet the standard of “highly useful” set in the legislation.

State, Local, and Tribal Law Enforcement Access

In particular, regarding state, local, or tribal law enforcement agencies, the CTA has very straightforward language: FinCEN should disclose beneficial ownership information upon receipt of a request from a state, local, or tribal law enforcement agency “if a court of competent
jurisdiction, including any officer of such a court, has authorized the law enforcement agency to seek the information in a criminal or civil investigation.”

Contrary to this plain language and intent of the law, the proposed rule increases – with no foundation – the standard that state, local, and tribal law enforcement must meet to access the database in two key ways. First, the proposed rule requires that a requesting agency submit to FinCEN “copy of a court order from a court of competent jurisdiction authorizing the agency to seek the information in a criminal or civil investigation” as well as a “written justification that sets forth specific reasons why the requested information is relevant to the criminal or civil investigation.” A “court order” is a term of art more stringent than the CTA’s statutory language of “court authorization.” Requiring a court order increases the burden on investigators to justify their use of the database in investigations, as well as on courts themselves, by requiring most likely a judge to complete the order.

This leads to the second issue: the practical impact of a court order requirement contradicts the statutory language that “any” officer of competent court of jurisdiction can approve a request, and increases the risks of clogging up courts with administrative burdens. Moreover, Congress considered and rejected more restrictive requirements such as obtaining a court order or subpoena or ascertaining that a requesting agency’s request be reasonably relevant and material to an investigation. Legislators settled on the “authorization from a court officer” deliberately, and to lower barriers to usage and formalism in the request.

We encourage FinCEN to stay within the confines of the law and drop artificial new requirements that will limit effective access.

Access by Foreign Competent Authorities

In regards to foreign requesters, the CTA allows U.S. government agencies to make requests of the database on behalf of foreign law enforcement officials for countries that have existing information sharing agreements or that are “trusted foreign countries.” The proposed rule seeks feedback on whether FinCEN should define the term “trusted foreign countries.” We believe that the agency has appropriate flexibility to determine this list in accordance with potential shifting realities within other governments or in U.S. foreign relations, but we encourage FinCEN to define and follow some principles, in the interest of fostering multilateral law enforcement collaboration.

FinCEN is correct that the CTA has left the Bureau discretion in the determination of “trusted foreign countries.” But the approach and metrics to make such a determination, and motivation for changes to it over time, should be understandable and accessible. For instance, once a country X is deemed as “trusted” for the purposes of a request, denying other requests from the same country could fuel a sense that certain companies are less deserving of scrutiny than others. The determination that country X is “trusted” could, of course, change over time, but there should be clarity on the change and what justifies it. As currently drafted, the rule seems to leave too much room for case-by-case assessments. Failure to observe some consistency would ultimately harm US interests in maintaining bilateral arrangements for information sharing with the countries in question.

Access by Financial Institutions

In terms of financial institutions access, we believe they should have full, uncomplicated access to ownership records in the database following appropriate protocols. Further, we believe FinCEN has too narrow of a read on how financial institutions can use this information. While FinCEN’s proposed rule states that financial institutions can only use this information to carry out their antimoney laundering obligations under the 2016 Customer Due Diligence Rule (CDD Rule), it instead should allow financial institutions to use this information pursuant to all their customer due diligence obligations – e.g. anti-fraud or sanctions screening – required by applicable law.

The proposed rule suggests financial institutions information-retrieval process will be on more limited basis than that granted to law enforcement, which we find may render the registry less useful in combating illicit activity and create restrictions that have dubious grounds in the CTA and consistency with its spirit and purpose.

Verification of Data

Finally, we find the proposed rule fails to go far enough into the specifics of database design that will ensure its searchability and data quality yield the “highly useful” results for law enforcement the CTA intended. We proposed that FinCEN adds steps to verify data, but the proposed rule merely states the agency is considering options to do this “within the legal constraints in the CTA.”

There are multiple ways FinCEN can resort to existing information to verify beneficial ownership information reported by companies, and it should take advantage of as many of them as possible. Partnerships with the U.S. State Department, National Law Enforcement Telecommunications System or the U.S. Postal Service, among others, are viable options. Verifying the data is the best way to ensure the efficacy of the CTA database, and to make the information in the database highly useful to law enforcement and national security officials.

Conclusion

Corporate transparency will have a major impact in reducing international corruption, thereby providing vulnerable populations with the means to access resources for building schools, hospitals, and the infrastructure necessary for development. Additionally, the collection of beneficial ownership information will make it harder for those stealing from the most vulnerable to use the United States financial system as a safe haven to hide their money. Jubilee USA Network looks forward to working with FinCEN during its rulemaking on the Corporate Transparency Act to
ensure this mission is achieved.

In closing, we thank you again for your consideration of these comments. For any questions or clarifications on our comments please feel free to contact Aldo Caliari at [email protected].

Sincerely,

Aldo Caliari
Senior Director of Policy and Strategy

*Reflection of this broad support is a letter we organized last year in which more than a 100 religious organizations, congregations, faith-based communities and others urging U.S. Senators to support the Corporate Transparency Act (available at http://www.jubileeusa.org/jubilee_usa_anti_money_laundering_act_of_2020_letter)

Download the New York State Public Employees Federation (PEF) support memorandum for The New York Taxpayer and International Debt Crises Protection Act as a PDF here.

Download the New York State Public Employees Federation (PEF) support memorandum for The New York Taxpayer and International Debt Crises Protection Act as a PDF here.

Download the Catholic Climate Covenant support memorandum for The New York Taxpayer and International Debt Crises Protection Act as a PDF here.

Download the Catholic Climate Covenant support memorandum for The New York Taxpayer and International Debt Crises Protection Act as a PDF here.

Download the Eurodad support memorandum for The New York Taxpayer and International Debt Crises Protection Act as a PDF here.

Download the Eurodad support memorandum for The New York Taxpayer and International Debt Crises Protection Act as a PDF here.

Responsibilities

• Helping write, edit and design educational, grassroots, and marketing materials
• Coordinating Jubilee's social media strategy 
• Writing and disseminating press materials
• Posting content to various local media platforms
• Ensuring the website and blog are updated
• Designing graphics and leading creative projects
• Conducting media research and corresponding with reporters
• Providing administrative support in the following areas: 
  • Data management: Adding or updating contacts in our databases and maintaining key website pages 
  • Office functions: Assisting with mailings and other related administration to support Jubilee’s communication efforts
  • Jubilee USA sponsored events: Helping with event preparation, taking notes during events, and participating in post-event reflection
• Attending coalition meetings with leaders from allied organizations
• Drafting summary memos to senior leadership as needed
• Attending virtual events on behalf of Jubilee USA
• Working with staff on other priority projects as needs arise

Qualifications

Ideal candidates have an interest or experience in working with social media, external communications, and/or basic graphic design. We're looking for strong attention to detail, robust writing skills, social media savvy, the ability to balance competing priorities, and enthusiasm for collaborating in a team setting with people of diverse backgrounds. Best suited for those interested in working in the press, external affairs or communications. Knowledge of or interest in economic justice issues is a plus. Positive attitude and enthusiasm is a must!

To Apply

To apply, email your updated resume to [email protected] and include the name of the position(s) you are seeking in the subject line. Please mention if you are open to multiple positions in your email if that is the case. We are accepting applications on a rolling basis and have the capacity to take on four to six associates in the cohort. While this is an unpaid internship, we enthusiastically work with the student and their college to offer academic credit. The Summer term runs from May 27th to August 17th. Note: This internship can be completed entirely virtually but preference may be given to Associates who can participate in person.

The Development & Executive Associate works closely with the Communications and Outreach Director and other Associates to implement our campaigns by strengthening our relationships with donors and streamlining our systems. This position includes organizing donor information, running reports, and advising the Director on opportunities to improve organizational capacity. This role can be flexible and grow to fit the Associate's evolving interests, skills, and career goals.   

Responsibilities

• Streamlining operational systems 
• Implementing key processes for tracking progress on development goals 
• Interfacing with small-dollar donors
• Organizing and contributing to grant proposals
• Assisting with online donor fundraising
• Preparing fundraising appeals and reports
• Updating and writing web and print materials for donor outreach
• Providing administrative support in the following areas: 
  
  • Data management: Adding or updating contacts in our databases and maintaining key website pages 
  • Office functions: Assisting with administrative processes to support Jubilee's outreach programs
  • Jubilee USA sponsored events: Helping with event preparation, taking notes during events, and participating in post-event reflection
• Attending coalition meetings with leaders from allied organizations
• Drafting summary memos to senior leadership as needed
• Playing a key role in organizing and coordinating logistics for Jubilee USA events as applicable
• Attending events on behalf of Jubilee USA
• Working with staff on other priority projects as needs arise

Qualifications

Ideal candidates have an interest or experience in database management, development, and nonprofit administration. We're looking for strong attention to detail, basic familiarity with Excel, robust communication skills, the ability to balance competing priorities, and enthusiasm for collaborating in a team setting with people of diverse backgrounds. Knowledge of or interest in economic justice issues and/or different faith traditions is a plus but not required. Positive attitude and enthusiasm is a must!

To Apply

To apply, email your updated resume to [email protected] and include the name of the position(s) you are seeking in the subject line. Please mention if you are open to multiple positions in your email if that is the case. We are accepting applications on a rolling basis and have the capacity to take on four to six associates in the cohort. While this is an unpaid internship, we enthusiastically work with the student and their college to offer academic credit. The Summer term runs from May 27th to August 17th. Note: This internship can be completed entirely virtually but preference may be given to Associates who can participate in person.

Position Overview

The Policy Associate works closely with the Communications and Outreach Director and other Associates to implement our advocacy campaigns by tracking policy issues and working with coalition partners. This position includes a wide range of research, writing, outreach, lobbying, and education. This role can be flexible and grow to fit the Associate's evolving interests, skills, and career goals. 

Responsibilities

• Attending coalition meetings with leaders from allied organizations
• Drafting summary memos to senior leadership as needed
• Researching and writing materials for outreach to policymakers and the public
• Maintaining Jubilee's policy lists in relevant databases
• Updating advocacy and policy content on Jubilee's website
• Tracking Jubilee's policy areas
• Communicating with partners about current activities and campaigns
• Providing administrative support in the following areas: 
  
  • Data management: Adding or updating contacts in our databases and maintaining key website pages 
  • Office functions: Assisting with administrative processes to support Jubilee's grassroots, development, and policy activities
  • Jubilee USA sponsored events: Helping with event preparation, taking notes during events, and participating in post-event reflection
• Attending events on behalf of Jubilee USA
• Working with staff on other priority projects as needs arise

Qualifications

Ideal candidates have knowledge of or an interest in domestic and international economic policy issues. We're looking for strong attention to detail, robust writing skills, academic and/or professional research experience, and enthusiasm for collaborating in a team setting with people of diverse backgrounds. Working toward or having completed an undergraduate degree in economics, finance, public policy, or related field is a plus but not required. Positive attitude and enthusiasm is a must!

To Apply

To apply, email your updated resume to [email protected] and include the name of the position(s) you are seeking in the subject line. Please mention if you are open to multiple positions in your email if that is the case. We are accepting applications on a rolling basis and have the capacity to take on four to six associates in the cohort. While this is an unpaid internship, we enthusiastically work with the student and their college to offer academic credit. The Summer term runs from May 27th to August 17th. Note: This internship can be completed entirely virtually but preference may be given to Associates who can participate in person.

Spectrum News 1 Discusses Jubilee USA's New York bill to fight developing countries' debt crises and address supply shocks. Below is a brief excerpt. Click here for the full article.

NY lawmakers, advocates want pressure for developing nations' creditors

By Nick Reisman

For the Rev. Nicolle Jean-Simone, helping her husband's native Haiti often comes from personal pleas. 

"We receive calls from family members, friends, missionaries telling us the needs of what's going on in the country and we do our very best to support them," she said. "But what if we could do it also through legislation."

Jean-Simone was among the advocates on Wednesday at the state Capitol calling for a measure that would require the New York-based creditors of developing nations facing a mountain of debt to help with relief and restructuring efforts. 

The goal is to make it easier for those countries to pay the debt back and in turn help the residents of those countries who have struggled with ongoing crises. 

Read more here.

On Wednesday, a high-level panel explores the role of IMF emergency currency or Special Drawing Rights in pandemic recovery. The event, Special Drawing Rights and Global Pandemic Recovery, is convened by Jubilee USA Network and features Ambassador Sam Brownback, former US Senator and US Ambassador at Large for International Religious Freedom, Africa Union Ambassador Hilda Suka-Mafudze and President of Bread for the World, Reverend Eugene Cho.

“We need to do more to address the health and economic crises spurred by the coronavirus," shared Jubilee USA Executive Director Eric LeCompte. LeCompte will introduce and moderate the panel. “The event focuses on a type of aid that countries can use for pandemic recovery.”

In August, the IMF issued $650 billion in Special Drawing Rights (SDRs) or emergency currency for countries to address the coronavirus crises. More than $400 billion of the aid went to wealthy economies, with the US receiving $113 billion. Wealthy countries can transfer their unused SDRs to countries in need.

“Already this aid is making a difference for countries responding to the crisis,” added LeCompte. "Wealthy countries can share the SDRs they won't use with developing countries."

The IMF accepts SDRs from countries to finance zero-interest loans for the poorest countries. Another IMF vehicle under development will accept SDR contributions to assist developing small states and vulnerable middle-income countries. Recent research released by Jubilee USA Network and LATINDADD determined the emergency currency can help overcome pandemic-related weaknesses in 24 Latin America/Caribbean countries.

To receive a link to ask questions and virtually attend, "Special Drawing Rights and Global Pandemic Recovery,"register here. Alternatively, you can join through Facebook Live: https://www.facebook.com/jubileeusa/

Read about Jubilee USA's research on SDRs and pandemic challenges facing Latin and Caribbean countries here.

The World Trade Organization postponed a meeting where trade ministers planned to decide on vaccine access and production issues for developing countries. The meeting, scheduled for Geneva, Switzerland, was canceled because of new travel restrictions due to the COVID Omicron variant. Waiving pharmaceutical company patents on COVID vaccines and treatments featured prominently on the agenda.

“The World Trade Organization can help ensure that everyone around the world can access coronavirus vaccines and treatments," said Eric LeCompte, the Executive Director of the religious development organization Jubilee USA Network. "In spite of the lack of an in-person ministers meeting, the WTO can still take action on waiving vaccine patents."

The highest WTO decision-making body in between ministerial meetings is the General Council.

The IMF estimated that failure to achieve a 70% vaccination rate globally by mid-2022 will result in more than $5 trillion in global economic losses over the next five years. While vaccination rates in high-income countries approach 70% of the population, less than 5% of people in low-income countries received even one dose, according to a group of World Health Organization experts.

"Distributing vaccines is essential to stop food shortages and prevent economic shocks," stated LeCompte.

In the summer, Jubilee USA organized leaders of the Catholic, Methodist, Episcopal, Lutheran, Presbyterian and United Church of Christ Churches and AFL-CIO to meet US Trade Representative Ambassador Katherine Tai on the vaccine and trade proposals. Tai supports temporarily waiving COVID vaccine patents. 

Call the Capitol Switchboard at 202-224-3121 and ask for your Senators. You will need to call twice to reach each of your US Senators. The switchboard is open 24 hours a day and 7 days a week to leave a message for your Senator.

If you need help finding your Senators, you can ask the Capitol Switchboard attendant by telling them in what state you reside or use this link.

Once you are connected, ask to leave a time-sensitive message for your Senator.

"Thank you for taking my call. I live in your state, my name and address is______________. The Build Back Better Act contains provisions that will help Puerto Rico recover from debt crisis, natural disasters and tackle a nearly 60% child poverty rate. I want the Senator to promote recovery and opportunity for the people of the island by:

1.) Supporting Supplemental Security Income payments that could benefit more than 300,000 low-income people; 

2.) Support child tax credits and fully fund a permanent expansion of the healthcare Medicaid program;

3.) Passing measures to increase manufacturing jobs in Puerto Rico."  

The House of Representatives voted to increase Medicaid funding and incentives to support manufacturing jobs in Puerto Rico as part of the Build Back Better Act.

“This legislation means that Puerto Rico can access more resources that the island desperately needs,” said Eric LeCompte, Executive Director of Jubilee USA Network, which worked on debt and disaster relief for the island since 2015. "Faced with high poverty rates, debt crisis and natural disasters, Puerto Rico can really use the aid."

The Build Back Better Act provides Supplemental Security Income disability payments to Puerto Rico, benefiting 300,000 Puerto Rico residents. The bill includes the territory in child tax relief increases for the states. The legislation now heads to the Senate and if passed could be enacted into law this year.

In February, 20 major religious leaders representing Catholic, Methodist, Lutheran, United Church of Christ and Evangelical Churches wrote to President Biden to support Puerto Rico. Leaders of the National and Puerto Rico Council of Churches, Catholic Charities and the General Bible Society also signed the letter to Biden.

Read the Jubilee USA Puerto Rico and US Religious Leaders Letter to President Biden here.

Read the Puerto Rico Religious Leader Stimulus Letter to Congress here.

Open Letter to G20 Finance Ministers, Central Bank Governors and the IMF: Civil Society Organizations Call for Principles for Fair Channeling of Special Drawing Rights

We strongly believe that successful and equitable recovery is contingent on transparency and a participatory process inclusive of civil society in all countries. This also applies to international spaces making decisions on SDR channeling mechanisms, including the G20 and the IMF, where civil society has not had, so far, sufficient opportunities to engage on this matter.

We urge you to ensure SDR channeling options align with a basic framework of principles that many academics, experts and civil society colleagues around the world echoed over recent months.

THE CHANNELING OPTIONS SHOULD:

1. Provide debt-free financing, so it does not add to unsustainable debt burdens of developing countries, whose annual external public debt payments are projected to average US$300 billion over 2021 and 2022. Grant-based financing is ideal but, if additional loans are to be offered, then maximum concessionality is critical (zero interest and lengthy repayment terms with extended grace periods).
2. Refrain from tying transfers to policy conditionality (directly or indirectly). Conditionality will lengthen the time it takes to negotiate such financing, could force countries into adopting difficult adjustment or austerity measures; or put the financing beyond reach for countries unable to comply with such conditions.
3. Be accessible to middle-income countries. These countries have persistently been left out of debt relief initiatives and concessional financing, and should not be excluded from yet another financial assistance option when many of them face deep debt distress and challenging pandemic vulnerabilities.
4. Include transparency and accountability safeguards on both providers and recipients of such financing in the spirit of democratic ownership, strengthening independent scrutiny, participation and accountability to citizens.
5. Ensure that SDR contributions are additional to existing ODA and climate finance commitments. Only SDRs channelled to developing countries as grants should count as ODA, or, where appropriate, against the climate finance goal of US$100 billion.
6. Prioritize SDR use that expands international grant funding for combatting the pandemic through budget support for public services and the public sector workforce in health and education, for social protection and other needs. Grants can also target promotion of a fair recovery that supports climate justice, and tackles economic and gender inequality, including the unpaid care burden that women bear, and the COVID-19 pandemic exacerbated.

We also call for agreement on a global repository to report on channeled SDRs. This will help limit fragmentation and be an important measure for accountability of commitments and tracking the overall impact of SDRs, including for ongoing learning.

We are aware that the Poverty Reduction and Growth Trust (PRGT) is being considered as a favoured option for SDRs channeling; however, it is important to note that the PRGT does not reflect the principles of being debt-free, conditionality-free, and accessible to all developing countries. We urge you to consider ways to improve the PRGT option, including channeling via its emergency financing vehicle (Rapid Credit Facility).

We also encourage you to identify SDR channeling mechanisms that support debt cancellation, including through the Catastrophe Containment and Relief Trust, and to consider alternative options which align best with the principles stated above.

To create options to scale up SDR channeling volumes and reach more developing countries we encourage you to seriously discuss alternative options beyond the PRGT and beyond the IMF more broadly. However, other rechanneling vehicles under discussion, such as a Resilience and Sustainability Trust and Multilateral Development Banks, still appear far from embodying these principles.

Finally, neither the initial SDR allocation nor the channeling of SDRs can be a substitute for the urgent implementation of debt relief measures that benefit both low- and middle- income countries, especially to ensure that the additional resources are not directed to repay external private and other creditors.

Click here to add your signature.

SIGNATORIES

REGIONAL / GLOBAL ORGANISATIONS

1. Access to Human Rights International AHRI
2. Action Aid International
3. ACTIONS PLURIELLES
4. Advocacy Initiative for Development (AID)
5. Africa Network for Environment and Economic Justice(ANEEJ)
6. African Forum and Network on Debt and Development AFRODAD
7. African Women’s Development and Communication Network(FEMNET)
8. AidWatch Canada
9. Alliance for Sustainable Development Organization (ASDO)
10. Arab Watch Coalition
11. Associated Country Women of the World
12. Association Biowa
13. AULA TIDEs UN SDGs Action Education & Programming
14. Blue Ridge Impact Consulting
15. Both ENDS
16. Bretton Woods Project
17. Burundi Rugby League Rugby a XIII Cooperative, Central & East Africa
18. Campaign for Human Rights and Development International CHRDI, Sierra Leone West Africa
19. Campaña Latinoamericana por el Derecho a la Educación (CLADE)
20. Candid Concepts Development
21. Caritas Ghana
22. Center for Economic and Social Rights (CESR)
23. Christian Aid
24. Civil Society Action Coalition on Education for All
25. Coalition for Health Workers (HRH PLUS)
26. Confederation of Indonesia People Movement (KPRI)
27. Coordinadora de Organizaciones de Desarrollo
28. DAWN (Development Alternatives with Women for a New Era)
29. Derecho Ambiente y Recursos Naturales DAR
30. Development Alternatives
31. Diverse Voices and Action (DIVA) for Equality
32. Ekumenická akademie (Ecumenical Academy)
33. Equidad de Género: Ciudadanía, Trabajo y Familia
34. Estonian Roundtable for Development Cooperation
35. European Network on Debt and Development EURODAD
36. Feminist Task Force
37. FENASSEP/ISP, SINERGIE DES TRAVAILLEURS DU TOGO/STT
38. Fight Inequality Alliance
39. Fight Inequality Alliance, Asia
40. Financial Transparency Coalition
41. FOKUS - Forum for Women and Development
42. Fundacion para Estudio e Investigacion de la Mujer
43. Fundación para la Democracia Internacional
44. Fundacion SES
45. Gender and Development Network
46. Génération Maastricht
47. Geneva Finance Observatory
48. Global Campaign for Education
49. Global Coalition Against Poverty GCAP
50. Global Policy Forum
51. Global Socio-economic and Financial Evolution Network (GSFEN)
52. Global Youth Online Union
53. Health Action International Asia Pacific
54. Indigenous Peoples Global Forum for Sustainable Development, (International Indegeous Platforme)
55. Institute for Economic Justice
56. Institute of the Blessed Virgin Mary - Loreto Generalate
57. Internacional de Servicios Públicos (ISP)
58. International Council for Adult Education
59. International Women’s Rights Action Watch Asia Pacific (IWRAW Asia Pacific)
60. Jubilee Debt Campaign
61. Jubilee USA Network
62. Ladies of Great Decorum
63. Latin American Network for Economic and Social Rights -LATINDADD
64. Latinoamérica Sustentable
65. Medicus Mundi Mediterrània
66. Medicusmundi spain
67. Missionary Oblates of Mary Immaculate
68. Mumahhid Family of Greater Jerusalem
69. MY World Mexico
70. NGO CSW LAC
71. Okogun Odigie Safewomb International Foundation (OOSAIF)
72. OXFAM
73. Plateforme française Dette et Développement (PFDD)
74. Red de Justicia Fiscal para América Latina y El Caribe RJFALC
75. Regions Refocus
76. RIPESS
77. SAUDI GREEN BUILDING FORUM
78. Save the Children
79. SEATINI
80. SEDRA, Chile
81. Seed Global Health
82. Servicios Ecumenios para Reconciliacion y Reconstuccion
83. Sisters of Charity Federation
84. Social Justice in Global Development
85. Society for International Development SID
86. Stakeholder Forum for a Sustainable Future
87. Stop the Bleeding Campaign
88. Success Capital Organisation
89. The Kvinna till Kvinna Foundation
90. Third World Network
91. Tripla Difesa Onlus ODV
92. UDA LLP
93. UGANDA DEBT NETWORK
94. UNISC International
95. Unite for Climate Action
96. United Religions Initiative
97. WaterAid
98. Wemos
99. Womankind
100. Women Coalition for Agenda 2030
101. World Future Council
102. World Public Health Nutrition Association
103. Zamara Foundation

NATIONAL ORGANISATIONS
104. AbibiNsroma Foundation, Ghana
105. Academic and Career Development Initiative, Cameroon
106. Africa Development Interchange Network (ADIN), Cameroon
107. Alliance Sud, Switzerland
108. Al-Tahreer Association for Development, Iraq
109. American TelePhysicians, USA
110. Apostle Padi Ologo Traditional Birth Centre, Ghana
111. Asociación Ciudadana por los Derechos Humanos, Argentina
112. Association for Promotion Sustainable Development, India
113. Association of Rural Education and Development Service, India
114. Baghdad Women Association, Iraq
115. Bahrain Transparency
116. Budget Advocacy Network, Sierra Leone
117. Catholic Agency for Overseas Development CAFOD, UK
118. CCFD-Terre Solidaire
119. CDES, Ecuador
120. CEDECAM, Nicaragua
121. Cedetrabajo, Colombia
122. CEICOM, El Salvador
123. Center for Economic and Policy Research, CEPR
124. Centre for Environmental Justice, Sri Lanka
125. Civil Society SDGs Campaign GCAP Zambia
126. CLATE/ULATOC/CTA-A, España
127. Club Ohada Thies, Senegal
128. CNCD-11.11.11
129. Comisión Nacional de Enlace
130. Community Working Group on Health (CWGH), Zimbabwe
131. Conservation and Development Agency CODEA-CBO, Uganda
132. Consumer Unity and Trust Society (CUTS), Zambia
133. Cooperation for Peace and Development (CPD), Afghanistan
134. Corporación CIASE
135. Debt Justice Norway
136. DECIDAMOS. Campaña por la Expresión ciudadana
137. DSW Kenya
138. Economic Justice Network Sierra Leone
139. EMPOWER INDIA
140. ENVIRONICS TRUST, India
141. erlassjahr.de
142. Fair Trade Hellas, Greece
143. Fomento de la Vida- FOVIDA, Peru
144. Foro Social de Deuda Externa y Desarrollo de Honduras - FOSDEH, Honduras
145. Forum Solidaridad Perú
146. Foundation for Environmental Management and Campaign Against Poverty, Tanzania
147. Freedom from Debt Coalition, Philippines
148. Friends of the Earth US
149. Fundación Ambiente y Recursos Naturales (FARN)
150. Fundación Constituyente XXI, Chile
151. Gatef organizations, Egypt
152. GCAP El Salvador
153. GCAP Italia
154. GCAP Rwanda Coalition
155. German NGO Forum on Environment and Development
156. Gestos (soropositividade, comunicação, gênero), Brazil
157. Global Justice Now
158. Global Learning for Sustainability, Uganda
159. Global Responsibility (AG Globale Verantwortung)
160. GreenTech Foundation, Bangladesh
161. GreenWatch Dhaka, Bangladesh
162. Group of Action, Peace and Training for Transformation - GAPAFOT, Central African Republic
163. GWEN Trust, Zimbabwe
164. Help Age, India
165. Institute for Public Policy Research, Namibia
166. Instituto de Estudos Socioeconomicos, Brazil
167. Instituto Equit - Genero, Economia e Cidadania Global,Brazil
168. Instituto Guatemalteco de Economistas, Guatemala
169. Iraqi center for women rehabilitation & employment, Iraq
170. Iraqi Institute for the Civil Development(IICD), Iraq
171. Jubilee Debt Campaign -UK
172. JUBILEO 2OOO RED ECUADOR
173. K.U.L.U.- Women and Developmennt, Denmark
174. Kathak Academy (KA)
175. Kulmiye Aid Foundation, Somalia
176. Lanka Fundamental Rights Organization, Sri Lanka
177. Marikana youth development organisation, South Africa
178. Movimiento Tzuk Kim-pop, Guatemala
179. Myanmar Youth foundation for SDG, Myanmar
180. National Association of Professional Environmentalists(NAPE), Uganda
181. National Campaign for Sustainable Development Nepal
182. National Confederation of Dalit and Adivasi Organisations (NACDAOR), India
183. National Labour Academy, Nepal
184. National Society of Conservationists - Friends of the Earth Hungary
185. NCD Alliance in Georgia
186. Nepal Development Initiative (NEDI), Nepal
187. Network of Journalists Living with HIV (JONEHA), Malawi
188. New Millennium Women Empowerment Organization, Ethiopia
189. NGO Federation of Nepal
190. Nkoko Iju Africa, Kenya
191. Observatorio Mexicano de la Crisis, Mexico
192. Okoa Uchumi Campaign, Kenya
193. ONG Cooperación y Desarrollo, Guinea Ecuatorial
194. ONG Espoir Pour Tous, Côte d’Ivoire
195. Ong FEED, Niger
196. ONG PADJENA, Benin
197. ONG Santé et Action Globale, Togo
198. Organisation des Femmes Aveugles du Bénin
199. Pakistan Development Alliance
200. Pakistan Fisherfolk Forum
201. Pakistan Fisherfolk Forum
202. Pakistan Kissan Rabita Committee
203. Peoples Development Institute, Phillippines
204. POSCO-Agenda 2030 Senegal
205. PROGRÈS SOCIAUX, Benin
206. Rapad Maroc, Morocco
207. REACHOUT SALONE, Sierra Leone
208. REBRIP - Rede Brasileira pela Integração dos Povos, Brazil
209. Recourse, The Netherlands
210. Red Dot Foundation Global, USA
211. Red Dot Foundation, India
212. Red Mexicana de Acción frente al Libre Comercio (RMALC)
213. RENICC Nicaragua
214. RIHRDO (Rural Infrastructure and Human Resource Development Organization )
215. Rural Area Development Programme (RADP), Nepal
216. Rural Infrastructure and Human Resource development Organization (RIHRDO), Pakistan
217. SAFE EMPOWERED COMMUNITIES ASSOCIATION ZAMBIA
218. Sisters of Charity Federation
219. Social Economic and Governance Promotion Centre, Tanzania
220. Solidarité des femmes pour le Développement intégral (SOFEDI), R. D. Congo
221. Somali Youth Development Foundation (SYDF), Somalia
222. Sorouh for Sustainable Development Foundation-SSDF, Iraq
223. Stamp Out Poverty
224. State Employees Federation, Mauritius
225. SUSTAINABLE DEVELOPMENT COUNCIL, India
226. SYNAPECOCI, Côte d’Ivoire
227. Tanzania Coalition on Debt and Development (TCDD)
228. Tax Justice Network US
229. The Institute for Social Accountability, Kenya
230. The Mango Tree, Kenya
231. The Rural Sector Public Institution CBO and Affiliated Entity’s With Multiple Distinct Components, Bangladesh
232. Toto Centre Initiative, Kenya
233. Treat Every Environment Special Sdn Bhd, Malaysia
234. Uganda Peace Foundation
235. UIMS, Iraq
236. UndebtedWorld, Greece
237. Union des Amis Socio Culturels d’Action en Developpement (UNASCAD), Haiti
238. Uso Inteligente ASV A.C., México
239. VEILLE CITOYENNE TOGO
240. Wada Na Todo Abhiyan, India
241. WEED - World Economy, Ecology & Development e.V.
242. Western Kenya LBQT Feminist Forum (Lets Be Tested Queens CBO)
243. WIPGG Nigeria
244. WomanHealth Philippines
245. Women in Democracy and Governance (WIDAG), Kenya
246. Working With Women, Cameroun
247. WREPA, Kenya
248. Za Zemiata, Friends of the Earth Bulgaria
249. Zukunftskonvent Germany
250. Hawad Organization for Relief and Development

ACADEMICS / RESEARCHERS
251. Ahmad Mahdavi, University of Tehran/ and Sustainable agriculture and environment
252. Albert Gyan, Social Advocate (African Diaspora)
253. Annina Kaltenbrunner, Leeds University Business School UK
254. Brenda Awuor Odongo, Researcher on SRHR and Reproductive health
255. Claudio Schuftan, Researcher on human rights
256. Daniel Bradlow, Professor of Law at American University Washington College of Law
257. Daniel Ortega-Pacheco, Center for Public Policy Development, ESPOL Polytechnic University, Ecuador
258. Dr. Adamu Abdullazeez Bako, Centre for Citizens Rights
259. Elisa Van Waeyenberge, SOAS University of London
260. Frances Stewart, University of Oxford
261. Gabriele Koehler, Researcher on 2030 Agenda eco-eco-social state, Germany
262. Gerry Helleiner, Prof. emeritus, Economics, University of Toronto
263. Grupo de Investigación en Derechos Colectivos y Ambientales GIDCA, Universidad Nacional de Colombia
264. Ilene Grabel, Distinguished University Professor, Josef Korbel School of International Studies
265. Jorge Manuel Gil, Cátedra libre pensamiento latinoamericano, UNPSJB
266. Kevin P Gallagher, Global Development Policy Center, Boston University, USA
267. Lena Dominelli, University of Southampton, UK
268. María José Lubertino Beltrán, Profesora de Derechos Humanos, Universidad de Buenos Aires
269. Martin S. Edwards, Seton Hall University, School of Diplomacy and International Relations
270. Matthew Martin, Development Finance International
271. Michel Aglietta, emeritus professor in economics, Centre for Prospective Studies and International Information CEPII
272. Nora Fernández Mora, Pontificia Universidad Católica del Ecuador
273. Oscar Ugarteche, Instituto de Investigaciones Económicas, México
274. Remco van de Pas, Researcher on public health at ITM
275. Rick Rowden, Lecturer, American University in Washington DC
276. Rungani Aaron, Researcher, Zimbabwe
277. Sandra Janice Misiribi, Good Health Community Project
278. Shem Atuya Ayiera, ST. HEMMINGWAYS NGO
279. Spyros Marchetos, Aristotle University of Thessaloniki, Greece
280. Viktor Chistyakov, Columbia University

As the climate summit approaches its final days in Scotland, 200 countries negotiate an agreement to combat climate change. A key outstanding item is enacting the 2015 Paris agreement pledge to provide $100 billion to developing countries annually to deal with climate challenges. The OECD forecast that the financing pledge won't be met until 2023.

“Developing countries are dealing with a range of climate driven challenges from natural disasters to food shortages,” said Eric LeCompte, Executive Director of the religious development organization Jubilee USA Network. “We can't wait years for developing countries to get funding to combat the climate crisis. The crisis is now.” 

During COP26, Jubilee USA pushed world leaders to consider debt relief and using IMF emergency currency, or Special Drawing Rights, to fund the climate financing targets.

“World leaders should be looking at a range of ways to support funding for developing countries to deal with the climate crisis,”  noted LeCompte.

China and the US released a declaration pledging cooperation for a successful conference outcome and recognizing the importance of the $100 billion commitment.  

As climate talks continue in Scotland, new research shows that developing countries lack the resources to respond to the climate crisis.

"The Glasgow meetings are critical to protect our planet and the poor who suffer the worst impacts of climate change,” said Eric LeCompte, Executive Director of the religious development group Jubilee USA Network. “Climate-induced natural disasters and food shortages disproportionately affect developing countries."

Ahead of COP26, Jubilee USA Network and LATINDADD released the Atlas of Vulnerability, focused on 24 Latin American and Caribbean developing countries. The map and research found 75% of countries fall below the global average in country capacity to respond to climate change.

"Debt relief can be an effective tool for helping developing countries take action to respond to climate-caused challenges," noted Jubilee USA's Senior Policy Director, Aldo Caliari. Caliari was one of the authors of the new climate research and wrote a paper last year on debt, climate and pandemic response.

The IMF calculates that developing country costs to deal with climate change rises to $140 billion to $300 billion by 2030. According to the United Nations, half of developing countries pay more than 25% of their budgets servicing debt. In October, 48 vulnerable countries asked for a process to use debt relief to support climate action.

“Developing countries struggle with rising debt levels and responding to the pandemic,” added LeCompte. “Debt relief and additional aid are essential for developing countries as they fight climate change."

In 2009 wealthy countries promised $100 billion in annual financing to developing countries by 2020. According to the OECD, developed countries provided almost $80 billion in 2019 and according to 2020 estimates, it was unlikely that the $100 billion target was met. COP26 brings together delegates from 200 countries to agree on climate actions. The meeting in Glasgow, Scotland comes six years after the Paris Agreement, a deal to address the earth's warming temperature caused by fossil fuel use.

Explore the interactive Jubilee USA Network and LATINDADD Atlas of Vulnerability: Developing Countries and the Pandemic here.

Read highlighted findings from the Atlas of Vulnerability here.

Read the briefing paper "Atlas of Vulnerability: The Pandemic in Latin America and the Caribbean" here.

Read the paper on debt and climate from Jubilee USA's Aldo Caliari here.

286 Organizations Call G20 to More Action

A new online map highlights vulnerabilities that countries face in Latin America and the Caribbean. Jubilee USA Network and LATINDADD, two groups working on pandemic response, published the new online database detailing growing challenges faced by developing countries due to the pandemic.  

"Our new database and map is a resource for world leaders to make decisions on the growing health and economic challenges that countries face because of the pandemic," noted Eric LeCompte, Executive Director of one of the groups that created the research map, Jubilee USA Network. "This information can help the G20 and IMF make decisions with real data that shows the pandemic impacted the income of countries in sectors like tourism," continued LeCompte. "We can see that developing countries had challenges before the coronavirus that made the pandemic worse."

The Atlas of Vulnerability highlights limitations developing countries face in responding to the pandemic. The research and map focus on 24 Latin America and Caribbean countries. 

"Our map brings together the whole range of economic, social and climate weaknesses that cripple pandemic response in developing countries.” said Patricia Miranda, Global Advocacy Director of LATINDADD. “The result of the research overcomes artificial categories of developing low- or middle-income countries. In Latin America, middle-income countries are the majority and were left out by global recovery policies."

Currently, only countries categorized by the World Bank as low-income can access emergency debt payment relief and other pandemic relief measures. The two groups argue that this approach may dangerously underestimate how middle-income countries are suffering pandemic damage.

The map includes data from 12 vulnerability dimensions: external sector, fiscal sector, private sector, health system preparedness, education, employment/social security, food/nutrition, climate, gender, poverty, inequality and physiological conditions. 

The online interface allows the viewer to see up to 55 indicators, find the top five vulnerability factors, pull up historical performance and compare with benchmarks from developed economies for each country. 

Some key data findings the map shows include:

• For more than half of the countries, tourism dependence is higher than the world average.
• Regional governments paid an interest rate 7.5% higher than that paid by the U.S. to borrow from international markets.
• Tax revenue as a share of the economy is below the average in industrialized countries, except in one country. In 6 countries, it is less than half the average. 
• In most countries, the number of people who died in the first year of the pandemic is more than 10% higher than the previous five year average, with four countries exceeding 55%. The average across Latin America is 2.7 times higher than in OECD countries.
• Five countries have COVID-19 vaccination rates under 5% and only three countries reached more than 40%.
• In more than half of the surveyed countries, less than 12% of the population can access any type of social safety net program, and it is only above 40% in one country.
• More than 75% of countries show less climate response capacity than the global average.
• More than 20% of people live in poverty in all but two of the countries, and poverty rates rose in all countries during the pandemic.

"The pandemic exacerbated developing countries’ vulnerabilities and we suffer the impacts now. If global policies don’t take them into account, recovery will take longer for our countries and our people, where women and girls bear the highest burden,” said Veronica Serafini, LATINDADD’s Gender and Macroeconomics Officer.

Developing country pandemic response is on the agenda for G20 leaders when they meet in Rome at the end of October.

“The hope is that presenting the data in this way will provide a clearer picture of the challenges in developing countries,” shared Aldo Caliari, Jubilee USA's senior policy director. “We need more action from wealthy countries so developing countries can confront the global crisis.”

On Wednesday, Jubilee USA and LATINDADD host a virtual event to present and provide a short tutorial on the map as well as discuss its findings with the UN Economic Commission on Latin America and the Caribbean, the International Labor Organization, and Climate Service Center of Germany. 

Explore the Atlas of Vulnerability: Developing Countries and the Pandemic here.

Read selected findings from the Atlas of Vulnerability here.

Read the full brief "Atlas of Vulnerability: The Pandemic in Latin America and the Caribbean" here.

Register for the map launch and virtual tutorial on October 27, 2021, 10:00 AM ET here.