April 2018

Contents:
• FATF Private Sector Consultative Forum
• De-risking of NPOs
• Regional: FATF-Style Regional Bodies
• National: Mutual Evaluation Reports
• Risk Assessments
• Spanish-language toolkit
• G20

FATF Private Sector Consultative Forum (PSCF): The Global NPO Coalition on FATF was represented by members from around the globe at the annual FATF Private Sector Consultative Forum in Vienna in April, delivering a strong message that NPOs need to be included in all phases of FATF Recommendation 8 implementation, and that the problems of financial exclusion/de-risking facing NPOs need to be addressed as a priority. The readout of the two-day meeting is here, including the Global NPO Coalition presentation on de-risking, a compilation by the FATF of some of the other presentations made at the PSCF, follow-up action points, a list of NPO participants and a lovely photo too!

De-risking of NPOs:
A new study by Human Security Collective and the European Center for Not for Profit Law looks at how global regulations on money laundering and terrorism financing permeate policymaking, influencing institutions (perversely, at times) and negatively impacting humanitarian and development work. By delving into the practices and perspectives of relevant stakeholders – NPOs, financial institutions, governments, regulators and international organizations – the study unpicks the mechanisms of governance and accountability involved in and through the chain of decision-making, underscoring the policy incoherence that is manifest along the way. Amplified by the three country contexts of Brazil, Mexico and Ireland, ongoing remedial measures addressing the financial exclusion of NPOs are highlighted and potential remedies that could challenge the current practice of de-risking explored in detail.

View the recording of a discussion on ‘The Impact of Bank De-risking on Nonprofit Organizations and their Beneficiaries in Conflict Areas’ organized by CSIS Human Rights Initiative, Charity & Security Network, and The Humanitarian Forum launching a series of country case studies on de-risking in conflict zones. During this event, expert panelists discussed the findings of the country case studies, with a focus on Syria, Yemen, Somalia, and Palestine.

A new study from the UK’s Charity Finance Group on the ‘Impact of money laundering and counterterrorism regulations on charities’ found that 79 per cent of charities face some kind of difficulty in accessing or using mainstream banking channels. The same number of respondents also said that banks had become ‘substantially or slightly more risk averse to them’. For more on the research findings, read here.

The report of the International Stakeholder Dialogue on ‘Ensuring Financial Services for Non-Profit Organizations’, held in The Hague in February and co-organized by the Dutch Ministry of Finance, the World Bank and Human Security Collective, with actionable follow-up suggestions, is here.

Regional:
GIABA, the FATF-Style Regional Body for West Africa, conducted a regional workshop in April on the ‘Development of effective frameworks and structures to fight against ML/TF through Non-Profit Organizations (NPOs)’ targeted at relevant regulators, policymakers and representatives from the non-profit sector. A representative of the Global NPO Coalition on FATF was invited as a resource person to facilitate a number of sessions during the workshop.

National:
FATF Mutual Evaluation Reports:
Ghana: Non-compliant on Recommendation 8 (the only non-compliant rating Ghana received), with the assessment calling for a sectoral risk assessment, better outreach to the sector, and more regulation and monitoring of NPOs.
Barbados: Non-compliant on Recommendation 8.

Risk Assessments:
Ever since FATF revised Recommendation 8 in 2016, countries must conduct a terrorist financing risk assessment of the non-profit sector. FATF requires government outreach to NPOs for these assessments, which are supposed to shape targeted, proportionate measures that only apply to NPOs at risk. How are governments and NPOs dealing with this process? How do risk assessments affect regulation of NPOs? How are they done? How can NPOs impact the process? Find out more in this recording of the webinar on the ‘ABCs for Risk Assessment of the Nonprofit Sector in Your Country’ organized by the Global NPO Coalition.

Spanish-language toolkit:
The International Center for Not-for-Profit Law has just published a Spanish-language toolkit for NPOs on ‘Anti-Money Laundering and Counter-Terrorism Financing Laws and the
Financial Action Task Force (FATF) Standards and Procedures’.

G20:
This FATF Report to the G20 Finance Ministers and Central Bank Governors on ongoing work to fight money laundering and terrorist financing includes tackling issues around financial inclusion and de-risking, calling for national regulators to reflect FATF guidance and for the G20 to clarify regulatory expectations.