International Activity Policy
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This international activity policy (“Policy”) sets out how OpenCollective Foundation (“OCF”) and projects fiscally sponsored under its umbrella (“Collectives”) may undertake activities involving people, organizations, or funding outside the United States (“US”).
Although OCF has donors from all over the world, our mission and impact is primarily focused on the US. There are situations, however, where we may allow certain international activities as exceptions. This Policy sets out guidelines we use to make decisions about whether to make such exceptions.
International activity that we can’t enable
Anything against the regulations OCF operates under as a US 501(c)(3) nonprofit organization;
Activity involving a country or region embargoed or sanctioned by the US government;
Activity involving individuals or entities included on the OFAC List of Specially Designated Nationals and Blocked Persons;
Payments to a country not served by our standard payment processors;
Violations of our policies that we apply to all activities;
Employing people outside of the US (however, we may be able to engage them as contractors if other criteria are met);
Making grants or in-kind contributions to a non-US individual or organization, or “Model C”-type grantor-grantee fiscal sponsorship, except in approved exceptional cases of international humanitarian aid; and
Initiatives focused on an international location/cause that are wholly led by American residents without demonstrated connections to that place or local project co-leaders.
OCF may be able to make special arrangements with highly-aligned international projects seeking funding only available to 501(c)(3) public charities. If you are such an international project working in the solidarity economy, contact us to discuss potential options.
Humanitarian aid is not easily defined. We generally understand it using the lens of the International Red Cross and Red Crescent Movement’s seven fundamental principles: humanity, impartiality, neutrality, independence, voluntary service, unity, and universality.
International activity we may enable
Applications for fiscal hosting
Prospective Collectives with non-US elements may be approved if they meet all of the following requirements:
Fit our eligibility criteria, with an enhanced requirement to be a well-established project with sufficient evidence of activities;
Can work according to our established operational processes, including how we receive and pay out money (e.g. we cannot make payments to countries not served by our payment processors); and
Have a significant connection to the United States and have at least one of the following:
An Administrator of the potential Collective that is based in the US;
Evidence the potential Collective has applied and been approved to receive a grant from a major US donor organization (501(c)(3) public charity, private foundation or donor advised fund, but in order to receive that grant, it must have 501(c)(3) status;
A main impact mission focused on the US (e.g. people organizing internationally for a US-specific cause);
A US-based team (e.g. a potential Collective with administrators in another country that plans to spend most of its budget paying US employees); or
Status as the US chapter of an international organization or network (as long as the chapter has its own separate budget from the international organization).
Collectives ineligible for fiscal hosting with OCF should explore other fiscal hosts on the Open Collective platform to see if there is a better fit!
Expenses
Collectives already hosted by OCF may pay international expenses, as long as the expense:
Fits with the Collective’s approved mission and purpose;
Follows our standard process and criteria for expense approvals and payments;
Is a reimbursement, virtual card charge, or invoice, with the usual required documentation/evidence provided (e.g., receipts);
Is to be made to an individual or entity not identified on the OFAC List of Specially Designated Nationals and Blocked Persons;
Is to be made to an individual or entity whose country is not sanctioned;
Is not a grant, cash assistance, or payroll expense; and
Follows the outside entities and outside accounts policies.
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