EU Supra National Risk Assessment Stresses Importance of NPO Participation in Addressing Counter-Terrorism Financing Challenges

The European Commission (EC) has just published its first Supranational Risk Assessment (SNRA). The SNRA assesses the vulnerability of various entities and services to risks of money laundering and terrorism financing; it found that non-profit organisations (NPOs) may be exposed to risks of being misused for terrorism financing purposes. To address this potential threat, it calls on the EC to organise multi-stakeholder exchanges with non-profits and to provide more guidance and/or training on the topic for non-profits receiving EU funding. It also recognises the concern that financial institutions may be reluctant to provide financial services to parts of the non-profit sector (so called bank de-risking) and that this should be addressed when developing policies in this area.

We are pleased that in drawing the recommendations for action, the EC did not opt for regulatory treatment but rather for soft law approaches, to be developed in a participatory manner with the NPO sector. This was a specific ask from the European NPOs of the Global NPO Coalition on FATF, under the lead of the European Center for Not-for-Profit Law (ECNL), the European Foundation Centre (EFC) and Human Security Collective (HSC). ECNL, EFC and HSC, in collaboration with Civil Society Europe (CSE), actively engaged with the EC in analysing potential supranational risk; we organised discussions among diverse groups of organisations, produced submissions to the EC and facilitated a wider exchange between non-profits at the EU level and the European Commission.

The SNRA draws from requirements of the Financial Action Task Force for all government actors to first identify risks to counter-terrorism financing and then adopt mitigating measures which respond to those risks in a proportionate manner. The SNRA falls within wider attempts to strengthen EU rules to tackle money laundering, tax avoidance and terrorism financing (see here). It will need to be repeated again in two years time.

As a follow up, ECNL, EFC and HSC in collaboration with CSE convened NPOs and transparency groups to discuss the results of the SRNA and agreed on steps to further engage with the European Commission around the report findings and suggested measures. If you want to be involved around the SNRA follow-up process, please contact

Non-profits are also keen to closely follow the development and implementation of the international counter terrorism and money laundering policy framework of the Financial Action Task Force (FATF). Those that wish to engage around the FATF processes and standards are also invited to contact the Global Coalition at