A December 2006 letter from Council on Foundations President Steve Gunderson on behalf of the Treasury Guidelines Working Group, which is made up of nonprofit sector organizations, international NGOs, grantmakers and legal experts calls for withdrawal of the Department of Treasury's Anti-Terrorist Financing Guidelines. Here are the main points: The letter acknowledges some improvements to the 2006 version of the Guidelines, but goes on to say, "These improvements notwithstanding, there continue to be areas in which the Guidelines raise legitimate concerns without furthering their stated purpose…." "First, the Guidelines significantly exaggerate the extent to which U.S. charities have served as a source of terrorist funding….[F]ailure to provide an accurate picture of the dollar amounts involved in terrorist abuse of charities results in overstatement of the risk that donations to legitimate charities may be diverted into the hands of terrorists." "Second, despite Working Group comments, the Guidelines continue to impose onerous information collection and reporting requirements that do little to protect charities from terrorist abuse. In addition, the latest version of the Guidelines includes troubling new provisions. Among these, the Guidelines advise that charities should not enter into relationships with grantees or employees 'where any terrorist-related suspicions exist,' and that charities report board members or key employees to Treasury if they find 'any suspicious activity relating to terrorism, including terrorist financing or other support, which does not directly involve an Treasury [list] match.' The Working Group believes that the quoted terms are vague and undefined and that reporting is inappropriate in the absence of solid evidence of terrorist-related activity." "Third, the Working Group remains concerned that Treasury has not gone far enough to ensure that the Guidelines remain voluntary." "Much of the work performed by U.S. charities around the world is designed to address the conditions that breed terrorism…The Working Group is concerned that many charities may not have the resources to fund the cost of complying with the Guidelines and will be forced to abandon work that is critical to the global fight against terrorism." "We continue to feel that the Guidelines and the accompanying Annex should be withdrawn and the Principles of International Charity endorsed in their stead." NOTE: The Principles of International Charity is a substitute for the Guidelines that the Working Group published in March 2005. A detailed analysis of the Guidelines, including their history and impact, can be found in the OMB Watch/Grantmakers Without Borders report Collateral Damage: How the War on Terror Hurts Charities, Foundations, and the People They Serve.