The FATF has adopted a procedure to address unintended consequences of its Standards on non-profit organizations (NPOs) during follow-up and grey-listing processes. To activate it, two parties are required: one FATF member and either another FATF member, an FSRB member, the IMF, or the World Bank. The mechanism applies to all FATF and FSRB members unless an FSRB opts out and establishes its own procedure. Unintended consequences reports can relate to any FATF standards that impact NPOs, not just Recommendation 8. NPOs themselves, those most directly affected, can not trigger it.

The Global NPO Coalition welcomes this step but remains concerned about its limited scope and the absence of space for civil society participation. In a recent joint letter from UN Special Rapporteurs also warned the FATF that without participation from NPOs, civil society, and independent human rights entities, the procedure risks being ineffective and lacking legitimacy. The Rapporteurs urged FATF to revise the mechanism to ensure meaningful consultation and allow those most affected by unintended consequences to play a direct role.