In 2021, The Financial Action Task Force (FATF) initiated a project to scrutinise the limitations and harmful impacts of the flawed implementation of its standards, in particular, Recommendation 8. In 2023, the amendments to Recommendation 8 (R8) strive to rectify the erroneous application and understanding of R8, which had caused countries to impose often excessive and restrictive measures on civil society. These measures hindered their capacity to function effectively, secure resources, and, in certain instances, sustain their lawful activities.
The revised R8 and its Interpretive Note will require countries to protect civil society from terrorist financing abuse through the risk-based implementation of strengthened measures. The newly adopted amendments clarify that focused, proportionate and risk-based measures are at the core of an effective approach in identifying, preventing and combatting terrorist abuse of civil society. When implemented appropriately, they are designed to protect the integrity of the civil society sector without unduly disrupting or discouraging legitimate civil society activities.
With that in mind, civil society organisations (CSOs) can effectively use the newly revised FATF standards and guidance document to:
- Underscore not all organisations are at risk of terrorist financing abuse;
- Advocate for governments not to apply the same regulations and measures to all of civil society;
- Ask governments to meaningfully include and consult civil society when addressing terrorism financing risk and before implementing any new regulations;
- Require the banks to have more nuanced approach to CSOs and not treat organisations as high risk;
- Raise awareness and educate themselves and colleagues on how to push back on harmful narratives and restrictions stemming from security and counter-terrorism space.
The document below helps CSOs navigate new FATF changes and outlines essential sections in the latest FATF R8, its Interpretive Note and Best Practice Paper, guiding CSOs to use these changes for their advocacy. It highlights the key focus of the recommendations from a CSO perspective, how and why the recommendations must be interpreted with a critical lens, and provides useful paragraphs to quote towards authorities, banks and other relevant stakeholders.
The document was translated into Albanian by Partners Albania for Change and Development. Find the document here.