While the government monitors the NPO sector for potential terrorism financing risk, and sets out rules on accountability and transparency, the NPO sector needs to monitor the measures imposed to ensure that they are proportionate to the risk and do not hamper legitimate charitable activity in any way.
BEST PRACTICE
Nigeria: Nigeria published a national risk assessment for TF and ML in 2016, which identified designated non-financial businesses and institutions (DNFIs), of which NPOs were a subset, as being among those sectors most vulnerable to ML/TF. Spaces for Change, a Global NPO Coalition member, challenged 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 Nigerian FIU and other government and NPO stakeholders, including GIABA (Intergovernmental Action Group Against Money Laundering in West Africa), the FSRB for West Africa. Sustained advocacy from Spaces for Change led to NPOs being delisted as DNFIs, and therefore no longer seen as obliged or reporting entities (as of May 2022). Furthermore, NPOs were fully engaged in the last sectoral risk-assessment process, with the country being adjudged fully compliant on Recommendation 8 in 2023.
