Engaging in risk assessment


Ideally the NPO sector would be at the table when the government is determining whether the sector is at risk of being abused for terrorism financing.

Conduct your own shadow risk assessment if either your government has not conducted one or has carried it out without involving the sector.

Make the case for the revision or repeal of legislation in line with the risk assessment, the mitigating measures suggested and the existing self-regulation measures in place.

Make sure the ‘no outreach to NPOs’ = ‘poor rating on Recommendation 8’ message is driven home to the government. 


  • United Kingdom: The 2017 National Risk Assessment assessed the risk of abuse of nonprofits for terrorism financing as ‘low’ . It also flagged the issue and impact of bank derisking on charities. The earlier 2015 National Risk Assessment  had assessed NPO risk to terrorism financing as ‘medium’.
  • Tunisia: State institutions (including the FIU, the General Directorate of Associations and Political Parties at the Presidency of the Government, the Anti-Terrorism Commission) and local NPOs collaborated effectively to update the risk assessment of the sector using a methodology provided by a Global Coalition member. The collaboration, and the work done on implementing Recommendation 8 in a way which protects civil society freedoms, has been much valued all round leading to Tunisia  being found Compliant with Recommendation 8 in 2019 – one of only six countries globally to be rated so. Just as importantly, there is now a genuine partnership between government and civil society on issues relating to possible TF risks in the NPO sector and measures to be implemented to mitigate these risks. The FATF has also now removed Tunisia from its ‘high-risk and other monitored jurisdictions’ list.
  • Nigeria: Nigeria published a National Risk Assessment for TF and ML (completed in 2016), which identified Designated Non-Financial Businesses and Institutions (DNFIs), of which NPOs are a subset, as being amongst those sectors most vulnerable to ML/TF. Spaces for Change, a Global NPO Coalition member, challenged (2019) this assessment of risk for the non-profit sector, disputing the official classification of NPOs as DNFIs and teasing out the nuances between vulnerability and threat, among other issues. The report led to increased and constructive engagement with the FIU (SCUML) and other government and NPO stakeholders, including GIABA, the FATF-Style Regional Body for West Africa.


  • The ABCs for Risk Assessment of the Nonprofit Sector in Your Country: A Handout
  • Presentation on experiences working with NPOs and Governments on the Risk Assessment Process, including persistent misunderstandings and issues. See here.
  • Risk Assessment Scoping Paper: Read an appraisal here of how the risk-based  approach and the Mutual Evaluation form the cornerstone to validating the effectiveness of Recommendation 8.