Mutual monitoring


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. 


  • Nigeria: Nigeria published a National Risk Assessment or 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.