After a year of consultation with key stakeholders, including nonprofit organizations (NPOs), banks, the UN, the Financial Action Task Force (FATF) and governments, the multilateral Global Counterterrorism Forum (GCTF) has released their Good Practices Memorandum for the Implementation of Countering the Financing of Terrorism Measures While Safeguarding Civic Space. It notes the unintended consequences countering the financing of terrorism (CFT) measures can have when they are “not designed and implemented in a manner consistent with FATF standards.” This in turn “can have a chilling effect on the operations of NPOs, humanitarian actors, donors, and the financial sector.” The memorandum also notes that in some cases CFT measures have been deliberately abused. The Global NPO Coalition on FATF provided extensive input in this process.

The non-binding memorandum recognizes the key role civil society plays “in addressing conditions conducive to terrorism.” It recommends that countering the financing of terrorism (CFT) legal frameworks be based on a risk-based, proportionate approach that is consistent with states’ obligations under international humanitarian and human rights law. The memorandum sets out 27 specific practices organized around 1) implementation of legal and policy frameworks, 2) assessing and responding to the risk of terrorist financing abuse of NPOs, 3) derisking and challenges to accessing financial services, and 4) the need to advance and sustain multi-stakeholder dialogue.