FAQ

Much of the counterterrorism architecture was solidified after 9/11, when multilateral bodies such as the UN and the FATF were mobilized under intense pressure from the US. The global counterterrorism architecture has the UN at its centre, with its four-pillared strategy, its means of implementation of that strategy (through conventions, protocols and sanctions), and the implementing bodies themselves (the Global Compact entities). See more here. 

Countering the financing of terrorism (along with tackling money laundering and dealing with proliferation finance) is mainly the domain of the FATF and the FATF-Style Regional Bodies. 

The UN uses sanctions to counter the financing of terrorism and the FATF puts in place rules and regulations ('the Standards') to do the same.

See here and here for how you can begin your engagement and what the entry points might be. Forming a coalition to advocate on these issues is useful, as is involving umbrella bodies. 

Additionally, see here for how to engage in the sectoral Risk Assessment process and here for how to engage in the Mutual Evaluation process

Derisking occurs at the intersection of frameworks for security and regulation, which, in turn, are seemingly at loggerheads with the development imperative. The many stakeholders involved - government departments, regulators, banks and NPOs - have varying mandates and differing risk appetites, leading to policy incoherence. There is also a big ownership gap, with each pinning the blame on the other, and adopting a risk-avoidance instead of a risk-mitigation approach.

Currently, NPOs are bearing the brunt of this securitized and regulatory agenda. One way of addressing this is through sustained multi-stakeholder dialogue processes. For more short- and long-term solutions to the issue, click here.  

We welcome you to follow our work and use our resources for your advocacy. If you would like to join the Global Coalition, please drop us a mail at npos@fatfplatform.org

Some of the Coalition achievements so far include:

• Revision of Recommendation 8 and its Interpretive Note:  the June 2016 revision retracts the claim that the NPO sector is ‘particularly vulnerable’ to terrorist abuse.  
• Formalization of a risk-based approach, which means a more proportionate and context-specific implementation of the FATF Standards. For the NPO sector, this means that supervision and regulation needs to be risk-based and proportionate to the risk that remains after existing (self-)regulatory measures have been taken into account.
• Establishment of regular engagement between the FATF Secretariat and NPOs, which allows for more effective NPO participation. Including seats at the annual Private Sector Consultative Forum (since 2017)
• Awareness-raising and coalition-building at the global, regional and national levels.
• Criticism by the FATF of the wholesale derisking of NPOs at the G20 level.
• Creation of a specific online mechanism on the FATF website for NPO input ahead of country evaluations (see FAQ page on FATF website 'How can NPOs and civil society organisations provide input into FATF Mutual Evaluations?')
• Sustained advocacy and pressure, leading to the setting up of the FATF Unintended Consequences workstream in 2021 looking at de-risking, financial exclusion, NPO suppression, and the impact of a misapplication of the FATF Standards on human rights and due process.   
• Revision of Recommendation 8 and its Interpretive Note in 2023 to further clarify its objective (countries need to protect NPOs from TF abuse without disrupting and discouraging legitimate charitable activity) and scope (the standard applies to only a subset of the sector). It also emphasizes the role of sectoral self-regulation in mitigating risk, and the need for risk assessments to be evidence based. The revision makes clear that NPOs should NOT be obliged or reporting entities.
• Revision of the Best Practices Paper on the implementation of Recommendation 8 in 2023, which now also includes bad practices (so what countries should NOT do)

The Global NPO Coalition on FATF is a loose network of diverse nonprofit organizations (NPOs). The Coalition advocates for improvement in the quality and effectiveness of FATF Mutual Evaluations with sustained outreach to the NPO sector, and the effective, risk-based implementation of FATF Recommendations affecting NPOs, particularly Recommendation 8 (R8). The aim is to mitigate the unintended consequences of countering the financing of terrorism (CFT) policies on civil society in order that legitimate charitable activity is not disrupted. The advocacy agenda is driven by policy changes at the FATF/global/national level that require swift action and engagement by NPOs as well as by a bottom-up process emerging from impact felt by NPOs on the ground. 

The Financial Action Task Force (FATF) is an intergovernmental organization founded in 1989 at the initiative of the G7 to develop policies to combat money laundering. In 2001, its mandate was expanded to include terrorism financing.