Coalition co-chair Charity & Security Network has submitted an NPO Shadow Report to the FATF ahead of the United States’ upcoming Mutual Evaluation. The report provides an overview of key anti-money laundering and countering the financing of terrorism (AML/CFT) regulatory, policy, and legal developments affecting the U.S. nonprofit sector since the country’s last FATF Mutual Evaluation in 2016.

The report documents growing concern among civil society organizations, legal experts, funders, and financial institutions regarding the increasing instrumentalization of the U.S. AML/CFT framework to target significant segments of the NPO sector in a manner that is politically driven and not grounded in risk. Stakeholders describe a regulatory environment characterized by uncertainty, distrust, and fear, with adverse consequences for the delivery of essential services both within the United States and internationally.

The report is accompanied by an annex that details U.S. government actions affecting the nonprofit sector between 2017 and the present.