December 2017

CONTENTS:
1. From the FATF
a. Portugal
b. Austria
c. November Plenary outcomes
d. FATF President’s statement
2. Country-/Regional-level
a. Western Balkans
b. Australasia
c. UK
d. USA
e. Saudi Arabia
3. De-risking
a. Standard Chartered
b. World Humanitarian Action Forum event
c. Webinar, hosted by the Global NPO Coalition on FATF
d. Blog
4. Shrinking Space
a. European Foundation Centre and Funders’ Initiative for Civil                 Society Report
b. Policy brief
5. Other news
a. Data Protection
b. New logo for Global NPO Coalition on FATF

1. From the FATF: 
PORTUGAL: Mutual Evaluation Report for Portugal on the country's measures to combat money laundering and the financing of terrorism and proliferation: rated Partially Compliant on Recommendation 8 related to non-profits. 

AUSTRIA had been placed in the FATF’s enhanced follow-up process following its evaluation last year which had found deficiencies in its AML/CFT policy coordination as well as in its assessment of risk. This is the first follow-up report analysing Austria’s progress in addressing the technical compliance deficiencies identified. 

FATF NOVEMBER PLENARY: The outcomes of the FATF Plenary meeting held in November are detailed here. Among other matters, the Plenary discussed and adopted a report, The Financing of Recruitment for Terrorist Purposes, which sets out how terrorist organisations fund the recruitment of new members. The FATF also reiterated its commitment to financial inclusion by adopting a customer due diligence supplement to its 2013 FATF Guidance on Anti-Money Laundering and Terrorist Financing Measures and Financial Inclusion. For a commentary on this new guidance, see Charity & Security Network’s analysis here. 

PRESIDENT’S STATEMENT: In a statement, Santiago Otamendi, the FATF President, reiterated the fact that de-risking exacerbates financial exclusion, increases terrorism financing/money laundering risk and is not in line with FATF requirements. He also explicitly acknowledged the adverse impact such de-risking can have on non-profits. Read the full statement here.
2. Country-/Regional-level:

WESTERN BALKANS: Read a report here mapping key findings and recommendations for countries in the Western Balkans on FATF’s Recommendation 8 concerning non-profit organisations.

AUSTRALASIA: AUSTRAC (the Australian Financial Intelligence Agency), Bank Negara Malaysia and Pusat Pelaporan dan Analisis Transaksi Keuangan (PPATK), Indonesia’s Financial Intelligence Unit, conducted a regional Countering-the-Financing-of-Terrorism (CFT) risk assessment for the not-for-profit sector. Here is the report.

UK: The 2017 National Risk Assessment assessed the risk of abuse of non-profits for terrorism financing as ‘low’. It also flagged the issue and impact of bank de-risking on charities. The earlier 2015 National Risk Assessment had assessed NPO risk to terrorism financing as ‘medium’. Read RUSI’s commentary on the Risk Assessment here.

USA: This case study summarises the experience of the Charity & Security Network (C&SN), a diverse network of non-profit organisations (NPOs) in the United States that sought to provide input on US anti-terrorist financing laws to the Financial Action Task Force (FATF) during its mutual evaluation of the US. The evaluation took place between early 2015 and December 2016, spanning a period of significant changes in FATF’s recommendation and guidance relative to NPOs. After describing C&SN’s efforts and assessing the experience, this paper makes several recommendations for FATF and NPOs to consider for future evaluations.

SAUDI ARABIA: C&SN also submitted comments on Saudi Arabia’s Treatment of NPOs to the FATF Secretariat, given that the country is currently undergoing an FATF Evaluation, with a report due in 2018.
3. De-risking:

STANDARD CHARTERED has partnered with the World Bank and NGOs to launch a financial crime risk management academy for charities, and makes its internal compliance courses available to clients online for free. See more in this article here. 
 
WHAF: The World Humanitarian Action Forum (WHAF) held a roundtable discussion on ‘The Impact of De-risking on Humanitarian Organizations – Shared Risk: Shared Responsibility’. This roundtable – one of three – was led by the Humanitarian Policy Group at The Overseas Development Institute (ODI) and The London School of Economics, and supported by Human Security  Collective, Charity & Security Network, Islamic Relief Worldwide, Al Rayan Bank, Human Appeal, Al Khair Foundation, The Norwegian Refugee Council and Muslim Charities Forum. Discussed in detail were the problem itself, the practice of de-risking and the policy implications. For a recording of the sessions, see here. For a roundup of the de-risking roundtable by C&SN, go here. 
 
WEBINAR: The Global NPO Coalition on FATF hosted a webinar on working on solutions to the problem nonprofits with international activities face in accessing banking services. This follows on from two important studies that were presented in May. The webinar featured: 
• Sue Eckert on the World Banks/ACAMS Multi-Stakeholder Dialogue on NPO Financial Access
• Six members of the Global NPO Coalition with updates from advocacy efforts in Europe, South America and North America
• Jerry Brito, Director, Coin Center, on piloting use of cryptocurrency for grant-making and humanitarian emergencies
• Hanna Surmatz, European Foundation Centre, with an update from the recent FATF Plenary
For a recording of the webinar, go here. To view the slides, go here.

BLOG: Why is banking non-profits considered risky? And what can be done about it? Read more here about the drivers, the impact and the possible solutions to the de-risking of non-profits.
4. Shrinking space:

EFC and FICS REPORT: This report discusses how closing space for civil society affects development funders and actors, and how they are responding.

POLICY BRIEF: This policy brief by Helmut Anheier, John Burns and Jack H. Knott examines the changing policy environment for civil society organisations and reviews the reasons behind shrinking civic space. It also includes proposals for how G20 countries and civil society can relate in productive ways.
5. Other:

DATA PROTECTION: Why does the UK Data Protection Bill exempt the ‘risk profiling’ industry? Read more here about the pitfalls of risk assessment by private data-brokers.

NEW LOGO: We have a new logo for the Global NPO Coalition. We hope you like it!