The Financial Action Task Force (FATF) made important changes to the criteria it will use to evaluate countries’ implementation of Recommendation 8 (R8), its standard for government anti-terrorist financing regulation of nonprofits, at its October 2016 Plenary. The purpose of the changes is to make it consistent with the June 2016 revision of R8, which removed language that unduly characterized nonprofit organizations (NPOs) as being “particularly vulnerable” to terrorist financing abuse. The new methodology is found in Immediate Outcome 10 at pages 117-119 of FATF’s Methodology handbook. It adds helpful new criteria to ensure countries take a risk-based, proportionate approach to any regulation of NPOs. It implicitly recognizes the chilling impact such regulations may have by adding that they should not “discourage legitimate NPO activities.” The new methodology criteria will apply to future evaluations, implying that evaluations already underway will continue under the old Immediate Outcome 10. A comparison of the revised and old Immediate Outcome 10 is here.
FATF’s Plenary outcomes statement says: