The Platform

The Civil Society Platform on the FATF has been set up to ensure that civil society is effectively engaged in the debate on anti-money laundering and combatting terrorism financing. Our vision is to have a free and fully-enabled civil society operating space.

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EU presents initial findings in the EU Supra National Risk Assessment
Review, comments and input solicited

The European Coalition on the FATF would like to call on you to engage in the supranational risk assessment (SNRA) of money laundering and terrorist financing risks that the European Commission (DG Justice) is currently undertaking. Initial findings presented by the EC in an October 4, 2016 consultation meeting suggest that some NPO activities (collection and transfer of funds) are considered risks in terms of terrorism financing abuse and we have until the end of November to send more input on the European Commission's threats and vulnerabilities analysis. Click here for more detail. 
Nonprofits No Longer "Particularly Vulnerable": Changes to Recommendation 8 and its Evaluation Methodology 

The Financial Action Task Force (FATF) has revised its Recommendation 8 (R8) on nonprofits to no longer characterise them as being 'particularly vulnerable' to terrorist abuse, and made important changes to the Interpretive Note to this Recommendation. 
In addition, FATF made important changes to the criteria it will use to evaluate countries’ implementation of Recommendation 8 (R8). The purpose of the changes is to make it consistent with the revision of R8. The new methodology is found in Immediate Outcome 10 at pages 117-119 of FATF’s Methodology handbook. It adds helpful new criteria to ensure countries take a risk-based, proportionate approach to any regulation of NPOs. It implicitly recognises the chilling impact such regulations may have by adding that they should not ‘discourage legitimate NPO activities’. The new Outcome 10 is here.(For more details and for a comparison of the revised and old Immediate Outcome 10 see here)

NPOs are now wondering how their countries will react to these revisions and how they can ensure that national implementation is beneficial to nonprofits and in line with FATF's new risk-based approach.With this in mind, the Global NPO Coalition on FATF hosted a webinar on September 12 to discuss how we got here and what you can do to help shape the road ahead. The link to the webinar is here.

Detailed calendar of countries coming up for FATF assessment 

Countries due for assessment in the next few months: Panama/Dominican Republic/Barbados/Bermuda – 2Q/3Q 2016
Mongolia – Aug/Sep 2016
Ghana – Sep 2016
Kyrgyzstan, Ukraine – Oct 2016
Slovenia – Nov 2016
Denmark, Ireland – Nov/Dec 2016
Cambodia, Macau (China), Thailand –  4Q 2016
Nigeria -January 2017

The United Nations Special Rapporteur on the rights to freedom of peaceful assembly and of association, Maina Kiai, called on the Financial Action Task Force (FATF) to improve its cooperation with civil society and consider the sector's valuable contribution to the fight against terrorism. He commended FATF on its decision to revise its controversial Recommendation 8 (R8), which requires FATF member states to ensure that nonprofits are not used to fund terrorism. In recent years, oppressive governments have used R8 to crack down on dissent. He said that 'the approach to countering terrorist activity needs to shift from regarding NPOs as part of the problem, to embracing them as integral to the solution'. See here for the full statement, issued 18 April 2016. 


Tedx talk by Ben Hayes on how international rules on combatting the financing of terrorism are being used as a pretext for restrictive regulatory regimes that adversely affect the legitimate activities of non profit and civil society organisations across the world.

Civicus interviews representatives of the global coalition engaging with the FATF on the impact of anti-terror and anti-money-laundering legislation on civil society space and on what civil society organisations can do to combat this. Read the full interview here.