The Financial Action Task Force’s (FATF) Recommendation 8 (R8) on Nonprofit Organizations (NPOs) is among 40 standards it uses to evaluate country anti-money laundering/counterterrorist financing programs. FATF is now conducting an evaluation of the Kingdom of Saudi Arabia, with a report due in the summer of 2018. Under FATF procedures the June 2016 revised R8, which requires countries to apply a risk-based, proportionate approach to anti-terrorist financing regulation of NPOs, will be used to measure Saudi Arabia’s compliance. Because Saudi Arabia is a closed country where civil society rights are under harsh attack, it is not likely the R8 standard can be met. On October 31, 2017 the Charity & Security Network submitted comments to FATF, based on research of public records, that argue Saudi Arabia is using counterterrorism laws to target domestic dissent and “expressive organizations” in a manner inconsistent with FATF standards and the International Convention for the Suppression of the Financing of Terrorism. C&SN’s submission is available here.