October 2017


1. News from the FATF
2. National-level, including global coalition member work
a. Australia
b. Nigeria
c. Tanzania
d. UK
e. Czech Republic
f. Indonesia
g. Uganda
h. Brazil and Mexico
i. Kyrgyzstan
j. Kosovo
k. United States
3. Global coalition member work at the regional-level
4. Past events
5. De-risking
6. Relevant reads


• New FATF President and his agenda: Argentina has taken over the Presidency of the FATF for 2017-18. These are the priorities for the new President. De-risking of NPOs and the proper implementation of Recommendation 8 are both on the agenda.
 • FATF organised a FinTech and RegTech Forum recently – here are the outcomes
 • Recent Mutual Evaluation Reports:
 Both countries scored a ‘Partially Compliant’ on Recommendation 8, which will have follow-on implications for the NPO sector

• Recently published National Risk Assessments: AUSTRALIA. See more here on assessing risk and other national risk assessment /sectoral risk assessment reports.

• Work of Global NPO Coalition members at the national level:

o NIGERIA: A research report ‘Closing Spaces for Civil Society and Democratic Engagement in Nigeria’ was published by Spaces for Change. The first part, Beyond FATF: Trends, Risks and Restrictive Regulation of Non-Profit Organisations in Nigeria, examines the (in)adequacy of Nigeria’s anti-money-laundering and countering the financing of terrorism legal framework, and tries to determine whether there is an evidential link between the enforcement of FATF standards and the ever-broadening state endeavours closing down spaces for civil society in the country. The second part, Closing Spaces for Civic Engagement and Civil Society in Nigeria, generates a database of closing spaces in Nigeria, presenting the evidence related to excessive restrictions on citizens and civil society operations perpetrated under the guise of ‘national interest’, ‘national security’ and ‘other ML and FT’ considerations.

o TANZANIA: A workshop was held on the FATF standards and processes to share knowledge and potential strategies for engagement ahead of country’s evaluation in 2018.

o UK: Global NPO Coalition members have provided input to the UK government in the form of a civil-society-organisation (CSO) submission on risk assessment. CSOs proactively offered arguments and suggestions on how to shape the sector's risk assessment, ahead of UK’s upcoming FATF evaluation.

o CZECH REPUBLIC: A workshop was organised bringing together NPOs/foundations and government to prepare for the upcoming evaluation and encourage more NPO participation/outreach in the process.

o INDONESIA: Global NPO Coalition members have been raising awareness on the FATF among NPOs in Indonesia, as well as engaging the government and the Indonesian Financial
 Intelligence Unit.

o UGANDA: A webinar on FATF and how Ugandan NPOs can take part in and influence the follow-on evaluation process in the country took place earlier. This was based on a desk study ‘Financial regulation drivers for current restrictions of civil society in Uganda’.

o BRAZIL and MEXICO: Workshops were conducted by Global NPO Coalition members on the impact of FATF Recommendations, especially Recommendation 8, on civil society and civic space. These workshops took place under the aegis of Conectas in Sao Paulo, Brazil and UniDosc at ORT University Mexico City, Mexico. See more here.

o KYRGYZSTAN: Global NPO Coalition members have worked with national CSOs on developing a sectoral risk assessment report ahead of the 2017 evaluation. This was done in coordination with the government's own preparations for the evaluation visit.

o KOSOVO: Workshops on FATF standards and processes were conducted for local CSOs in order to share knowledge and potential strategies for engagement ahead of the country's risk assessment and evaluation in the next two years. In addition, a governmental working group assessing NPO risk was established, including representatives from civil society organisations.

o UNITED STATES: Implementation of revised R8 requires update of the manual bank regulators use when auditing banks. The current manual reflects the old R8, saying CSOs are high risk customers. This has contributed to problems accessing banking services. CSOs and banks have agreed on a draft revision of the manual and submitted it to regulators. The revision cited the revised R8.

Work of Global NPO Coalition members at regional level:

• GIABA, the Inter-Governmental Action Group against Money Laundering in West Africa (an FATF-Style Regional Body) organised a three-day regional workshop on Preventing Terrorist Abuse of Non-Profit Organisations (NPOs) in Lome, Togo, in June, 2017. Global NPO Coalition members were present at the meeting, and spoke about the ‘Consultation & Involvement of NPOs in the Mutual Evaluation Process (Pre-Onsite, During Onsite and Post-Onsite)’. See here for more.

• Global NPO Coalition members have established contact with other FATF-Style Regional Bodies including ESAAMLG (Eastern and Southern Africa Anti-Money Laundering Group), GAFILAT (The Financial Action Task Force of Latin America), MENAFATF (Middle East and North Africa Financial Action Task Force) and MONEYVAL (Council of Europe Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism) – all of whom have expressed interest in engaging with NPOs at the country-level to understand their concerns.

• The European Commission (EC) has 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 NPOs may be exposed to risks of being misused for terrorism financing purposes. In drawing recommendations for action, however, the EC opted for soft law approaches, instead of regulatory ones, to be developed in a participatory manner with the NPO sector. This was a specific ask from the Global NPO Coalition members, which organised discussions among diverse groups of organisations, produced submissions to the EC and facilitated a wider exchange between nonprofits at the EU level and the European Commission. See more here.

Financial Inclusion for Freedom and Security (2nd October 2017, The Hague)
 This interactive event showcased new research on the topic of shrinking space for civil society, and more specifically on the negative impact of counter-terrorism financing regulations on civil
 society space. See more here. A report will be published shortly.



The World Bank and the Association of Certified Anti-Money Laundering Specialists (ACAMS) held a second roundtable early in 2017 to help promote the access of humanitarian organisations to financial services and to discuss practical measures in terms of improving relations between NPOs and financial institutions; improving the regulatory and policy climate for financial access for NPOs; and building coalitions for sharing information and best practice. The report is here. Different work streams have been established to develop practical initiatives to further discuss and work towards some of the suggestions put forward during this meeting – the Global NPO Coalition is actively involved in the process.

De-risking and nonprofits: how do you solve a problem that no-one wants to take responsibility for? Ben Hayes, Lia van Broekhoven, Vanja Skoric

Financial Access for US Nonprofits. Sue Eckert, Kay Guinane and Andrea Hall

Tightening the Purse Strings: What Countering Terrorism Financing Costs Gender Equality and Security. Women Peacemakers Program & Duke Law International Human Rights Clinic

On Shrinking Space: A Framing Paper. Transnational Institute

If you have news or examples regarding similar processes or work in your country you wish to share with the members of the Global NPO Coalition, please send a short paragraph to
Sangeeta Goswami at npos@fatfplatform.org or sangeeta@hscollective.org