Emerging Issues

These are some of the related issues that the Coalition is also engaging on:


Apart from AML/CFT, sanctions regimes also adversely impact legitimate charitable activity. Many of our members are engaging at various levels on this issue.  

Global Coalition members have been part of a multi-stakeholder technical compliance dialogue for Syria-related humanitarian payments, resulting in this Risk Management Principles Guide for sending humanitarian funds into Syria and other high-risk jurisdictions.  

European Union 

Global NPO Coalition members from Europe have been engaging with the European Commission on the Supra National Risk Assessment (SNRA) process. This is the 2017 report and this, the update in 2019. The SNRA assesses the vulnerability of various entities and services to money laundering and terrorism financing, thereby posing a risk to the internal market.

NPOs remain concerned about the EC's terrorism financing threat rating for NPOs, in spite of increased NPO awareness and regulatory and self-mitigation measures in place. There are fears that such a rating could be an excuse to further close down NPO operating space. The Coalition is pleased that the EC has re-stated its concern about bank derisking and also appreciates the call to governments to engage the NPO sector in the conduct of National Risk Assessments and in the development of mitigation measures. 

The Coalition is now engaging on the EU's new anti-money laundering and countering the financing of terrorism framework  which calls for better implementation of the existing rules, a more detailed and harmonized rulebook, high-quality and consistent supervision, including by conferring specific supervisory tasks to an EU body, interconnection of centralized bank account registries and a stronger mechanism to coordinate and support the work of the Financial Intelligence Units (FIUs).  

UN Security Council Resolution 2462

The first comprehensive UN resolution on ‘Preventing and Combating the Financing of Terrorism’, it recognizes the work of the FATF and strongly urges all member states to implement the AML/CFT standards set forth by the task force. 
Reaffirms that any measures that member states undertake to counter terrorism should be compliant with their obligations under international humanitarian law, international human rights law and international refugee law. 

Coalition members are monitoring how the implementation of this Resolution will play out at the national level.