Nonprofit organizations (NPOs) have several opportunitites for advocacy around counter-terrorism financing (CTF) laws and policies that impede their work. At its April 18 consultation with NPOs in Vienna, Austria, the Financial Action Task Force (FATF) agreed to accept written comments on revisions to its Recommendation 8 (R8) on nonprofits and look at NPO-suggested revisions to the Interpretive Note (IN).

The Charity & Security Network joined a number of NPOs in Vienna for a productive meeting. FATF was interested in receiving suggestions on how to make its documents reflect an updated and risk-based approach after years of describing the organizations as “particularly vulnerable” to terrorist abuse. There was robust discussion on changes needed to R8 and the draft IN, with NPOs suggesting:

  • removing harmful language from R8 and revising it to reflect a risk-based, proportionate and targeted approach;

  • removing the newly proposed Know Your Beneficiaries, Associate NPOs and Donors due-diligence requirement, which is contrary to international humanitarian law;

  • clarifying terminology to refer to the subset of NPOs found to be at risk;

  • referring in the IN to state obligations towards international human rights law and international humanitarian law; and

  • removing the checklist of supervision and monitoring requirements from the IN and emphasizing a risk-based, targeted approach.

FATF recently concluded its comments period on R8 and accepted a redline version of the IN from NPOs that included suggestions on how to best revise that document, part of the R8 standard.

The NPO sector needs to come together to make its voice heard by taking part in these opportunities to comment on the final drafts of R8 and the IN via the Global NPO Coalition on FATF, which is co-chaired by the Charity & Security Network and Human Security Collective. Additional advocacy opportunities will take place here in the U.S., where CTF laws and policies pre-date the FATF’s new risk-based, proportional approach focused on effectiveness. U.S. NPOs should urge the U.S. Treasury Department to update several documents to align them with FATF recommendations.

NPOs not already involved in the Global NPO Coalition on FATF can join this important work by contacting the Charity & Security Network at [email protected].