Financial Action Task Force (FATF) Consultation and Dialogue Meeting with Non-Profit Organisations (NPOs)

The Financial Action Task Force (FATF) Consultation and Dialogue Meeting with Non-Profit Organisations (NPOs) was held on April 18, 2016 at the United Nations Office on Drugs and Crime (UNODC), Vienna, Austria. This year’s meeting focused on the FATF’s work to revise its standards on NPOs (Recommendation 8 and its Interpretive Note).


The consultation meeting  was attended by national governments, FATF President and Secretary General, staff from FATF Secretariat and some 30 NPOs/foundations and their networks.  The NPO/foundation representatives made clear, strong points about amending the current versions of FATF’s  policy documents in what was, overall, a constructive engagement. There was a clear call for an open consultation with the wider NPO sector on Recommendation 8 itself. This has led to the opening of a public consultation, in which FATF has asked for input from NPOs for a ‘limited and focused revision of Recommendation 8′.

Comments are due Friday April 29 at 18:00 CET (Noon, US Eastern Time). It is a major opportunity to address problematic language in the current version of Recommendation 8, that says NPOs are ‘particularly vulnerable’ to terrorist abuse. This language has contributed to excessively restrictive regulation of NPOs and also to the trend of banks derisking accounts for NPOs that operate internationally.

Additionally, there was an indepth conversation with concrete wording proposals from NPOs on the draft of the revised Interpretative Note. While the draft document already shows some  improvement, several red flags remain and need to be addressed to ensure that the policy reflects a risk-based and proportionate approach with regard to counter-terrorism financing measures. FATF will now incorporate the comments received at the meeting and will table a new revised version of the Interpretative Note for Member States to comment on and approve at the June 2016 FATF plenary. It is hoped that the recommendations from the NPO sector will be taken into account.