Tunisian civil society organizations, in collaboration with ICNL, have prepared a shadow report parallel to  Tunisia undergoing its FATF mutual evaluation process. The report seeks to provide the assessors with civil society perspectives on the impact of countering the financing of terrorism measures on the sector.

According to its findings, Tunisia’s implementation of FATF recommendations has contributed to the disruption of legitimate charitable and civil society activities. It raises concerns over the use of disproportionate and non-risk-based measures targeting nonprofit organizations, as well as the application of anti-money laundering and countering the financing of terrorism frameworks in ways that may restrict civic space.

It also highlights ongoing efforts to amend Tunisia’s Decree 88 on Associations, which could further constrain the work of associations, alongside increasing financial exclusion and banking challenges faced by civil society organizations.

The publication adds to growing regional and global discussions on the unintended consequences of FATF Recommendation 8 and the importance of ensuring that measures aimed at preventing terrorist financing are implemented in line with international human rights standards and do not unduly restrict the work of civil society. This is also reflected in the recent Weaponisation of the FATF Standards: A Guide for Tunisian Civil Society, which explores how recent institutional changes in Tunisia in terms of independence and oversight mechanisms have shaped the application of AML/CFT measures and the detrimental impact that has had on on civil society operational space.