The FATF is revising Recommendation 24, its Standard on Beneficial Ownership. Members of the Global NPO Coalition on FATF have been in consultation with the FATF Secretariat on this issue, along with other representatives of the private sector. Concerns have been raised about how the concept of beneficial ownership, essentially designed for for-profit entities, will apply to the not-for-profit sector, and whether such a blanket application is warranted at all in light of the risk based approach. Privacy concerns, as well as concerns around the duplication of effort have been flagged. Given the sector's continued challenges with the unintended consequences of the AML/CFT framework in its daily work, it was emphasized that any new FATF Recommendation 24 policy proposals should take into consideration the rights and fundamental freedoms that are at stake and balance them against the public interest, while conducting a thorough impact assessment. 

Read the full Coalition input here.