Hub Reconnected – Global Meeting 2022

Security/CT
28-09-2022
Main takeaways of the 2022 workshop of our Global Hub on AML/CFT held near Paris.
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Group of members of the hub sat in front of screen

Around 70 CSOs and activists from 45 countries gathered for 3 days in September 2022 to reconnect and strengthen their responses to AML/CFT-inspired restrictions on civic freedoms. Activists discussed key needs, lessons learned and suggestions for the ongoing  revision of key FATF standards, methodology and guidance documents. In addition, activists discussed emerging trends and issues of the use of digital technology for AML/CFT purposes and its impact on their work, including FinTech, biometrics surveillance, as well as online content moderation.

 

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Please find brief take-aways and resources from the workshops below. Click each title to expand text. 

1. Key needs expressed by Hub activists:

Step up capacity building
  • For self-regulation mechanisms;
  • For government officials, supervisors, banks, civil society;
  • For specifically for all stakeholders involved in the risk assessment processes. 
Increase CSOs solidarity
  • Working in a collective, with mutual peer support from diverse organisations.
  • Being aware of the modalities governments can employ to obstruct civic space and ways to counter them. Sharing experience between CSOs on global level is needed.
  • Sharing own knowledge and expertise at all levels and promoting cooperation.  
Enhance engagement between CSOs and other stakeholders
  • CSOs need capacity to engage with and collaborate on risk assessment process with governments. 
  • Build bank and financial intermediary expertise and CSO engagement to ensure more tailored guidance specific to CSOs.  
  • Educate financial authorities about civil society and state human rights obligations.  
  • Dialogue between CSOs and Financial Action Task Force (FATF) and FATF-style regional bodies (FSRBs) is needed.  
  • Establish multistakeholder dialogues on a country level between civil society, governments and the financial sector.

 

2. Key lessons learned by Hub activists from past work and engagement:

Strengthen CSO responses
  • Proactive response by civil society: self-regulation and self-risk assessment can be useful. 
  • CSOs need to invest sufficient time in the process to review practical findings, to address issues and to validate concerns. 
  • Quick mobilisation of diverse CSOs at national level is key.  
  • Internationalisation of issues can be instrumental in getting a response from the government but can also cause backlash. Country context is key.
Expand areas for information sharing 
  • Education on Recommendation 8 is crucial. 
  • CSOs are successful in raising awareness and educating banks and the Ministry of Finance about their concerns. 
  • CSOs need to engage governments with their expertise on AML/CFT, not just with human rights language.
  • CSOs have a right to know what makes them at risk (in a risk assessment report) and should be able to contest it
Build valuable collaborations 
  • Multi-stakeholder dialogues and the way they are set up and implemented makes a difference. 
  • Creating links with other initiatives and movements - e.g. inserting AML/CFT issues in Open Government Partnership initiative.  
  • Collaboration of CSOs on national, regional, global level on policy discussions can expose government restrictions and amplify voices of civil society. 
  • Building trust at all stages of the process among all stakeholders is vital. 
  • Strategically identify and educate diverse allies to strengthen CSO efforts (donors, media, banks…) 

 

3. Messages and suggestions for global standard-setting bodies driving AML/CFT policies, including the FATF:  

FATF and CSO engagement
  • Make it mandatory to engage with civil society / CSO sector / in risk assessment and mutual evaluation process in country. 
  • Formalise system for communication and information sharing with FATF-style regional bodies and feedback mechanisms. 
  • Open channels for CSO communication in between evaluation processes (follow up process).
Learnings between FATF and member states 
  • FATF should encourage member states to learn more and support CSO self-regulation as part of terrorist financing risk mitigating measures. 
  • FATF and FSRBs evaluators should understand better the country context for the purpose of evaluation.  
Clarifications and guidance  
  • Clarify in FATF guidance and methodology that risk based approach should mean presumption of zero risk and evidentiary basis for risk.  
  • FATF needs to provide more guidance on balancing between freedoms and rights on one hand and AML/CFT regulation on other. 
Recommendations to improve Mutual Evaluations 
  • Incorporate de-risking indicators in Mutual Evaluations Reports. 
  • Ensure Mutual Evaluation requires meaningful participation of CSOs.  

4. Strategic objectives from regional advocacy workshops: 

During the workshops, Hub members conducted regional strategic planning that resulted in concrete objectives for addressing the AML/CFT restrictions jointly. One proposed way forward is to improve collaboration between State and CSOs to increase mutual understanding – both for the government to understand the work and impact of CSOs as well as for CSOs to better understand the relevant standards, the responsibilities and impacts stemming out from AML/CFT regulation. Also, some Hub members raised the issue of CSOs operating in a restrictive environment in which they are targeted and/or disproportionality impacted by AML/CFT regulation. In such cases, there is not always room to engage with their governments directly. Based on this, another proposed way forward is to also open up and maintain relations and exchange with relevant international and regional bodies that can support push back interventions by CSOs on national level. 

Next Steps

ECNL will continue to support Hub members’ country level work through online and offline tools and resources to facilitate learning, mentoring and exchanges. We assist with local advocacy efforts and co-develop push back strategies. Additionally, we continue to engage with different stakeholders that are part of this process to facilitate cross-sector discussion about solutions.

 

Visit ECNL's Learning Center on Security and CT for more resources and stories from countries such as Serbia! And get in touch with us if you want to join our Hub and learn more! Follow the Global Hub on Twitter #ExpertHubAML_CFT for more insights!

Useful Resources:  

2022 Global Hub Meeting Agenda
Security/CT
Global Hub

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