Conduct relevant outreach with a multitude of stakeholders, including NPOs, government (various departments), financial institutions, regulators and regional/international bodies.
Continuous engagement on the issues at stake is key. This applies to both NPOs as well as to governments and FATF-Style Regional Bodies.
Governments are assessed on their outreach to the NPO sector and poor outreach often means a poor mark on the Mutual Evaluation. Make sure the ‘no outreach to NPOs’ = ‘poor rating on Recommendation 8’ message is driven home to the government.
For NPOs, in terms of capacity, it is ideal is there is an umbrella body or a coalition working on the issue, raising awareness in the sector and spearheading the advocacy work. NPOs should seek to engage with relevant government departments, the Financial Intelligence Unit, banks, and regulators. Engagement helps better the understanding of varying mandates, and helps in the working towards a solution.
BEST PRACTICE
Multi-stakeholder dialogues are widely recognized as the most effective approach for ensuring meaningful engagement between governments, NPOs, financial institutions, and regulators, particularly on issues such as risk assessment and financial access.
In the Netherlands, this approach has been institutionalized through a formal roundtable process involving Ministries of Finance and Foreign Affairs, the Financial Intelligence Unit, the Banking Association, NPOs, and banks. The platform is used to discuss AML/CFT-related challenges affecting the NPO sector, including financial access and de-risking, and has also informed engagement during FATF mutual evaluation processes.
Similar sustained engagement between government representatives and NPOs can be found in other countries such as Argentina, Nigeria, Austria, Germany, Uganda, Albania, and North Macedonia.
