Submit your comment on FATF counter-terror policies impacting non profit organizations

09-11-2015
Calling for a risk-based approach in FATF standards.

Financial Action Task Force (FATF) has launched an open and public communication inviting non-profit organizations (NPO) to submit comments and specific proposals on the Interpretive Note (IN) for Recommendation 8 (R8) so that the practical knowledge and experience from NPOs can be properly reflected in the IN.

The IN is a binding guidance for implementation of R8 on non-profit organisations. FATF's purpose in updating the IN is to make it consistent with the risk-based approach for anti-terrorist financing regulations, and to clarify what NPOs are covered by R8. This process could result in a much more civil society-friendly IN that we could use to push back against problematic restrictions on civil society.

The open and public consultation is a result of advocacy efforts of the Global NPO Coalition co-facilitated by ECNL, the European Foundation Centre (EFC), the Human Security Collective (HSC) and the Charity & Security Network (CSN). The Global NPO coalition already proposed revisions to the R8 and its IN in October, which are available here, with aim to better reflect the risk-based, proportionate and targeted approach governments should undertake. We asked that the FATF revises R8, not just the IN, as the risk based approach does require a revision/adaptation of both the IN and the R8 itself.

You can submit your comments for the consultation process by using the template provided on FATF's website by November 27.