The EU Global AML/CFT Facility in collaboration with The Third Sector Foundation of Turkey, a partner of the Global NPO Coalition, organized a two-day meeting (17-18 January, 2023) with NPOs from across on the country on a 'Risk-based and proportionate implementation of  FATF Recommendation 8 on NPOs'. This was the first time such an in-person cross-sectoral convening had taken place. 

Türkiye is on the FATF 'grey list'of countries identified as having strategic deficiencies in terms of its implementation of the FATF framework in general and is under increased monitoring.

In terms of the nonprofit sector, legislative changes in 2020, many of which related to the civil society legal framework and were ostensibly introduced to comply with FATF Recommendations, were deemed by the sector to be non-risk-based and disproportionate, thus hampering legitimate charitable activity. 

The FATF has emphasized in its statements since that Türkiye needs:

'to fully implement a risk-based approach to supervision of non-profit organisations to prevent their abuse for terrorist financing, taking steps to ensure that audits conducted are risk-based, that supervision does not disrupt or discourage legitimate NPO activity such as fundraising, and that sanctions applied are proportionate to any violations.'

It further adds that: 

'The FATF continues to monitor Türkiye’s oversight of the NPO sector. Türkiye is urged to demonstrate the implementation of the risk-based approach to supervision of NPOs in line with the FATF Standards.'

The meeting in Istanbul was an opportunity for NPOs to discuss the prevailing situation and determine how best to engage with the official process. The EU Global Facility is also providing technical assistance to the authorities on this and other matters related to the FATF framework, and it is hoped that a multi-stakeholder conversation bringing all relevant parties together can be convened at a later stage.