Tunisia: lessons in a successful multi-stakeholder engagement process

Watch this video (made by Al Kawakibi Democracy Transition Center) to learn more about the successful multi-stakeholder dialogue process between a civil society coalition and various government bodies (including the Financial Intelligence Unit - CTAF, the National Counter Terrorism Commission, the General Directorate of Associations) around a joint sectoral Risk Assessment and the FATF process in general. Here about the trust-building that enabled a sustained engagement, and resulted in a fully Compliant rating for the sector on Recommendation 8.     


Tunisia had been under a lot of pressure to reform its AML/CFT rules/regulations/institutions and bring them in line with global standards after being put on both the FATF and EU ‘blacklists’ (‘high-risk and other monitored jurisdictions’) in the recent past. With CSOs in Tunisia starting to feel the squeeze in terms of operational space, they began organizing themselves nationally and internationally to counter this.
A consortium including KADEM, HSC, Greenacre Group, ICNL and ECNL was set up to work on an effective Risk Assessment of the sector, preferably with buy-in from the FIU (Commission Tunisienne des Analyses Financières or CTAF). Coalition partner Amine Ghali (KADEM) wrote in December 2019:

‘Constructive discussions, centred on specific expertise provided by the consortium, yielded an agreement on the collaboration between state institutions and local CSOs in order to update the Risk Assessment of the sector using a new and innovative methodology (developed by Greenacre Group). During this past year, these state institutions (including CTAF, the General Directorate of Associations and Political Parties at the Presidency of the Government, the Anti-Terrorism Commission) and CSOs (ASF, Jamaity, ASDI and KADEM) have worked together to update the sectoral Risk Assessment, which was then presented by CTAF to MENAFATF [the regional FATF body]. The collaboration and the work done on Recommendation 8 in a way which protects civil society freedoms, and the relevant actions to be implemented to mitigate ML/TF risks within the NPO sector, has been much valued by the regional body.
As a result, at the latest MENAFATF plenary in Cairo (end of November 2019), Tunisia was found compliant with Recommendation 8 – one of only six countries globally to be rated so. Just as importantly, there is now a genuine partnership between government and civil society on issues relating to possible TF risks in the NPO sector and measures to be implemented to mitigate these risks.’

The FATF has also now removed Tunisia from its ‘high-risk and other monitored jurisdictions’ list.